JPK_V7 and transport, postal and courier services

Service-Tax

The JPK_V7M / JPK_V7K file is valid from October 1, 2020. With the entry into force of the new structure that entrepreneurs have to draw up and send to the tax authorities, many ambiguities have arisen. When reporting sales and purchases, taxpayers have various doubts as to the marking of transactions in the record part of the JPK_V7 file. One of them is the issue of possible marking with the code GTU_13 transport, postal and courier services when delivering goods together with transport. In this article, we will try to explain whether invoices documenting the sale of goods sent to the buyer covering the shipping costs should be marked with the code GTU_13 in the JPK_V7M / JPK_V7K file.

GTU codes in the file JPK_V7M / JPK_V7K

Active VAT payers are required to prepare and submit to the tax office a new JPK_V7M file (taxpayers using monthly VAT settlements) or JPK_V7K (taxpayers settling quarterly). The JPK_V7 structure is a combination of the VAT-7 / VAT-7K declaration (the declaration part of the JPK_V7M / JPK_V7K file) and the JPK_VAT file (the record part of the JPK_V7M / JPK_V7K file). However, the record part of the file has been expanded with a number of new reporting information that should be regularly submitted to the tax authorities. The elements of the new JPK_V7 file are indicated in the regulation of the Minister of Finance, Investment and Development on the detailed scope of data contained in tax declarations and records in the field of tax on goods and services.

Starting from the declaration for October 2020, taxpayers have, inter alia, obligation to mark selected transactions with appropriate GTU codes. Entrepreneurs can choose from 13 different GTU codes, but the catalog of transactions that these codes cover is much wider. Due to the fact that GTU codes apply only to certain types of goods and services, and the regulations do not define many issues directly, there are many questions and doubts among entrepreneurs who are forced to carefully analyze not only the VAT Act, but also the messages posted on the website Ministry of Finance or interpretations of these regulations. One of the codes causing problems in the interpretation of taxpayers is GTU_13 in relation to the sale of transport, courier and postal services. The GTU 13 code is used for the provision of services classified as PKWiU 49.4 and 52.1.

Code GTU_13 and transport, postal and courier services

A common practice among entrepreneurs selling various types of goods by mail order is the resale of transport, courier or postal services together with the goods. The shipping cost is then covered by the buyer. The entrepreneur may calculate the cost of transport on the invoice documenting the sale, increasing the value of the goods sold and on the invoice indicate the value received in one item or enter an additional item on the invoice - the cost of transport, courier or postal services.

GTU-13 codes must be included on each sales invoice documenting the transactions corresponding to the individual codes. If your sale covers different types of goods or services, it may happen that the invoice needs to be identified with several GTU codes. It should be borne in mind that also in the case of re-invoicing services, if the services that are marked with a given GTU code are re-invoiced, the entity re-invoicing the services is obliged to include the relevant GTU code in the record part of the JPK_V7 file.

When reselling transport, courier or postal services as part of the delivery of goods together with transport, taking into account the obligation to mark re-invoices with the appropriate GTU codes, the question arises whether such an invoice should be marked with the code GTU_13 - provision of transport services and warehouse management.

When delivering goods, where the accompanying service is the cost of transport covered by the buyer, it is assumed that the taxpayer does not provide a separate transport service, but only supplies the goods. The service of transporting these goods is then only an additional delivery cost. Therefore, this type of transaction should not be marked with the code GTU_13 in the JPK_V7M / JPK_V7K file. The same should be done also when a separate item of transport costs has been specified on the invoice documenting the sale of goods. In this case, we also do not show the code GTU_13 in the JPK_V7 file on the invoice documenting the delivery of goods as part of mail-order sales.

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Explanations of the Ministry of Finance regarding the markings in the new JPK_VAT file - code GTU_13 and the delivery of goods together with transport:

Should the transaction of delivery of goods with transport as a price-setting element, when the terms of delivery indicate that the supplier must deliver the goods to a specific place, GTU 13 should be marked?

Not. In the presented situation, the taxpayer does not provide a separate service of transporting goods, only the delivery of goods, and the service of transporting goods is an additional cost of this delivery, therefore in this case the indication GTU_13 does not apply.

Example 1.

As part of his business, Mr. Jakub sells online textbooks. The goods are shipped to buyers and the cost of transportation is paid by the buyer. Mr. Jakub documents each transaction by issuing an invoice with a separate item "transport cost". Should the invoice issued by him be marked with the code GTU_13 in the JPK_V7M / JPK_V7K file?

No, Mr. Jakub does not provide a separate goods transport service, but only the delivery of goods, and the goods transport service is an additional cost of this delivery. It means that in this situation the marking GTU_13 should not be used in the JPK_V7 file.