Codes of product groups on invoices - what do you need to know about them?


From October 1, 2020, all active VAT payers are obliged without exception to send a new JPK file structure in the form of JPK_V7M (for monthly settlement) or JPK_V7K (for quarterly settlement). Deliveries of sensitive goods, such as alcohol or cigarettes, and intangible services, such as advisory or marketing services, are subject to special control. Specially introduced codes of commodity groups on invoices are to enable tax authorities to identify such transactions and increase the effectiveness of identifying entities that trade sensitive goods.

New reporting form - JPK_V7M and JPK_V7K structure

January 1, 2018The legislator imposed on active VAT payers the obligation to send the JPK_VAT file monthly, which shows sales and purchase transactions subject to VAT, specifying both the seller (in the case of purchases) and the buyer (in the case of sales), as well as such elements of the invoice as : number, date of issue, date of sale, net amount and value of VAT including the applicable VAT rate.

Such knowledge enables tax authorities to have greater control in the field of VAT, which has currently contributed to the detection of a wide variety of irregularities, frauds and tax frauds. In accordance with the introduced obligation, since then active VAT payers were obliged to send the JPK_VAT file for monthly periods and VAT declarations for monthly or quarterly periods, depending on the form of settlements declared by the taxpayer on the VAT-R form.

In order to ensure even greater control of transactions made by taxpayers, the legislator introduced a new form of reporting - JPK_V7M and JPK_V7K structures. The new JPK replaced the previously sent JPK_VAT files and VAT declarations as early as October 1, 2020. According to the information provided in the information brochure of the Ministry of Finance, the new structure combines the information previously included in the VAT declaration and the JPK_VAT file, and also includes additional designations of individual types of transactions.

Detailed information on the new SAF structure is described in the article: JPK V7M and V7K - the new structure will replace the VAT declaration.

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Codes of commodity groups on invoices - types of transactions covered by the marking

In the new JPK file structure, the legislator specified 13 groups of goods and services (referred to as GTU), which the seller is obliged to "mark" on the sales invoice if the sale of a given good / service takes place. The individual GTU fields relate to:

  • GTU_01 - deliveries of alcoholic beverages with an alcohol content above 1.2%, beer and alcoholic beverages that are a mixture of beer and non-alcoholic beverages with an alcohol content exceeding 0.5% (CN from 2203 to 2208),
  • GTU_02 - delivery of goods referred to in art. 103 paragraph 5aa of the VAT Act,
  • GTU_03 - deliveries of heating oils not included in point (a). b, lubricating oils and other oils (CN from 2710 19 71 to 2710 19 83 and CN from 2710 19 87 to 2710 19 99, excluding plastic lubricants falling within CN code 2710 19 99), lubricating oils (CN 2710 20 90) and lubricating preparations (CN 3403, excluding plastic lubricants of this heading),
  • GTU_04 - deliveries of tobacco products, raw tobacco, liquid for electronic cigarettes and innovative products, within the meaning of the provisions on excise duty,
  • GTU_05 - deliveries of waste - only specified in item 79-91 of Annex 15 to the Act,
  • GTU_06 - deliveries of electronic devices and parts and materials therefor, exclusively specified in item 7, 8, 59-63, 65, 66, 69 and 94-96 of Annex 15 to the Act, as well as stretch film specified in item 9 of this Annex,
  • GTU_07 - deliveries of vehicles and parts (CN from 8701 to 8708).
  • GTU_08 - deliveries of precious and non-precious metals - only specified in item 1 of Annex 12 to the Act and in item 12-25, 33-40, 45, 46, 56 and 78 of Annex 15 to the Act,
  • GTU_09 - deliveries of medicinal products, foodstuffs for particular nutritional uses and medical devices - only subject to the notification obligation referred to in Art. 37av paragraph. 1 of the Act of 6 September 2001 - Pharmaceutical Law (Journal of Laws of 2021, items 974 and 981),
  • GTU_10 - delivery of buildings, structures and land and their parts and shares in the ownership right, including the sale of the rights referred to in art. 7 sec. 1 of the act,
  • GTU_11 - benefits for the transfer of greenhouse gas emission allowances referred to in the Act of 12 June 2015 on the greenhouse gas emission allowance trading scheme (Journal of Laws of 2021, items 332 and 1047),
  • GTU_12 - providing services, incl. advisory, accounting, legal, management, training, marketing, advertising, market and public opinion research, research and development works,
  • GTU_13 - provision of transport and warehouse management (PKWiU 49.4, 52.1).

The markings introduced by the legislator refer to transactions concerning specific groups of goods and services, starting from the sale after September 30, 2020. More information on item group codes can be found in the article: Identification codes for some goods and services in the new JPK file.

Marking transactions in practice

GTU symbols are indicated directly in JPK files. The seller is obliged to mark the transaction, so the buyer is not obliged to do so, even if the purchased goods or services are among the 13 groups specified by the Ministry of Finance. Marking the codes of commodity groups on invoices consists in indicating the digit "1" in the new SAF-T structure for a given GTU to the invoice that documents the sale of a specific good or service. If the invoice is not for the sale of one of the 13 groups of goods and services, the field is left blank. Thus, the amounts of individual goods / services are not distinguished, but only the indication of the occurrence of a given GTU. Detailed information on the designations, types of goods and services can be found in the Regulation of the Minister of Finance, Investment and Development of October 15, 2019 on the detailed scope of data contained in tax declarations and records in the field of tax on goods and services. As indicated above, the obligation to mark GTU applies to the JPK_V7 file. Therefore, the legislator did not introduce an obligation to mark goods and services on sales invoices and warehouse documents issued to them. Therefore, the seller decides whether GTU markings will appear on sales invoices, who may enter symbols, e.g. in the description of the invoice, in order to mark them correctly in the JPK_V7 file sent to the MF.

Codes of commodity groups on invoices and the obligatory marking with GTU symbols do not apply to sales recorded at the cash register or in the form of non-account sales records. The markings are also not applicable in the case of purchases resulting in the appearance of output VAT, e.g. in the case of intra-Community acquisition of goods, import of services.

Commodity group codes on simplified invoices

A receipt that meets the following conditions is considered a simplified invoice:

  • has the buyer's tax identification number,
  • the value of the transaction is no more than PLN 450 or EUR 100,
  • specification of goods and services,
  • indication of the net value and the amount of VAT.

A receipt with the buyer's NIP (tax identification number) for the amount below PLN 450 or EUR 100 is not considered a simplified invoice if he documents:

  • intra-community delivery of goods,
  • sales to natural persons,
  • Mail Order,
  • the supply of taxable goods or services in the territory of an EU country other than Poland, for which the obligation to tax the transaction is transferred to the buyer.

A receipt with the buyer's tax identification number that meets the conditions to be considered a simplified invoice may be shown in the JPK_V7 file together with a daily or monthly report, depending on the method of settlements. So on such a receipt it is not necessary to add the GTU marking as it is not required on the reports.

If the receipt contains transactions that would require marking with the GTU code, then if the seller issues an invoice to it for the receipt, then in the JPK file it will be necessary to assign the GTU code to this invoice.

Although the intention of introducing a new JPK structure is a simplification of the reporting process - the taxpayer is obliged to submit one JPK file instead of the JPK_VAT file and VAT declaration - in practice, the taxpayer is obliged to accurately mark the types of transactions made in detail. A mistake preventing the identification of the transaction by the tax authority may cost the taxpayer at least PLN 500, as this is the penalty for one error in the JPK file. Therefore, it is not necessarily a real facilitation of the reporting process, at least from the taxpayer's point of view.

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Codes of commodity groups in the system system users have the option of indicating GTU codes at the time of issuing a sales invoice, thanks to which the codes of commodity groups will be automatically included in the JPK_V7 file. In order to indicate GTU codes at the time of issuing the invoice, first go to the SETTINGS »TAXES» TYPE OF TRANSACTIONS IN JPK V7 »GTU tab, where in the displayed window there is a list of thirteen GTU codes, among which the user-specific designations should be clicked and click SAVE. .

Giving the GTU code for sales transactions in the system is possible with the following package:

  • Invoicing + Warehouse
  • Online accounting
  • Online accounting + extensive warehouse

Then, in order to issue a sales invoice in the system with the GTU code, use the tab REVENUE »SALES» EXHIBITION »INVOICE / DRAFT INVOICE in the displayed window in the field for adding the product name, there is an additional GTU column, where the correct GTU code should be indicated.

After saving the invoice, the GTU code will be visible in the invoice preview window, but it will not be visible on the invoice printout.