JPK correction - in what situations should it be submitted?

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From January 1, 2018, approximately 1.6 million micro-entrepreneurs joined the group of VAT taxpayers who keep electronic VAT records (i.e. VAT sales and purchases register) and send it as JPK_VAT. Large enterprises send JPK_VAT from July 1, 2016, and small and medium-sized ones from January 1, 2017. However, we must remember that there may be a situation when it will be necessary to correct SAF-T.

What is JPK_VAT?

JPK_VAT is a set of information about purchases and sales, which results from the VAT records for a given period. It is sent only in an electronic version, in a specific format and format, by the 25th day of the month for the previous month, even if the taxpayer has to pay quarterly.

"JPK_VAT is nothing else, only accurate data reflecting the records of purchase and sale, which taxpayers are to keep so far in paper or electronic form in order to submit a correct VAT declaration. It is the translation of records into a certain scheme that functions in a uniform way among all taxpayers " (statement by Zbigniew Wiliński, Deputy Director of the Tax Collection Department).

What must the records of purchases and sales contain?

The obligation to keep records for tax on goods and services is provided for in Art. 109 paragraph. 3 of the Act of March 11, 2004 on tax on goods and services (i.e. Journal of Laws of 2017, item 1221, as amended), hereinafter referred to as the "VAT Act". This regulation does not provide for a form of registration, but it should enable the correct determination of the amount of tax. Pursuant to the above provisions, taxpayers, with the exception of taxpayers who perform only activities exempt from tax pursuant to art. 43 sec. 1 of the act or regulations issued on the basis of art. 82 sec. 3 of the Act and taxpayers whose sale is exempt from tax pursuant to art. 113 paragraph. 1 and 9 of the Act, are required to keep records containing:

  • the amounts specified in Art. 90 of the Act, i.e. the amount of input tax related to activities in relation to which the taxpayer is entitled to reduce the amount of tax due;
  • data necessary to determine the subject and base of taxation;
  • the amount of tax due;
  • the amounts of input tax that reduce the amount of tax due and the amount of tax to be paid to the tax office or refunded from this office and other data used for the correct preparation of the tax declaration;
  • in the cases specified in art. 120 paragraph 15, art. 125, art. 130d, art. 134 and art. 138 data specified by these provisions necessary for the proper preparation of the tax return.

Who does not submit JPK_VAT files?

If the entrepreneur (taxpayer) benefits from the exemption from tax on goods and services indicated in the VAT Act, there is no obligation to submit JPK_VAT. This applies to situations where the taxpayer:

  • sells only goods and provides services exempt from VAT (objective exemption - Article 43 (1)),
  • sells goods and provides services that are subject to VAT, but benefits from a subjective exemption (pursuant to Article 113 paragraph 1 or 9), because its turnover was less than 200,000 zloty.

Attention!

If the taxpayer's turnover is less than 200,000 PLN, but he resigned from the subjective exemption or he has no right to choose this exemption (referred to in Article 113 paragraph 1 or 9) - must submit JPK_VAT.

JPK correction

If we find an error in the settlement, we must submit a JPK_VAT correction. At this point, it should be emphasized that the JPK correction should be submitted only for the periods for which we were previously obliged to submit JPK_VAT.

Example 1.

As a result of the verification of his accounting entries, the taxpayer found errors that affect the VAT settlement for January 2015. Although he is required, being an active VAT taxpayer, to send JPK_VAT from January 1, 2018, he is not obliged to submit JPK_VAT corrections for January 2015 (he was not obliged to submit JPK_VAT during this period).

File structure and a submitted JPK correction

As mentioned above, JPK_VAT consists of the taxpayer's identification data (e.g. name, NIP) and data related to sales and purchase documents. JPK_VAT reflects the data contained in the records of purchase and sale. The data shown in JPK_VAT should be consistent with those included in the VAT declaration. We only send the file electronically. The structure of the uniform file for the records of purchase and sale (JPK_VAT) consists of the following tables:

  • Heading
  • The entity in which the data identifying it are contained (NIP, name of the entity).

The JPK_VAT structure has been modified over the years. They were caused by an improvement in functionality. JPK_VAT records for January are sent according to the new JPK_VAT structure3. If the taxpayer wants to correct the files sent before the billing period starting in January 2018, he must do so in the new structure.

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Example 2.

In February 2018, the taxpayer noticed that he made a mistake in the VAT settlement for September 2017. He was obliged to send the JPK_VAT records from January 1, 2017. When sending a JPK_VAT correction, the taxpayer must do it in the JPK_VAT3 structure, i.e. the structure in force in 2018.

When do we submit a JPK_VAT correction?

Taxpayers settling VAT for monthly periods (submitting VAT declarations monthly) are obliged to submit a JPK_VAT correction immediately after correcting the VAT-7 declaration or after receiving information about entering incorrect contractor data. In the case of taxpayers settling VAT on a quarterly basis, adjustments for individual months should be submitted immediately after identifying the errors justifying it in the file. If the values ​​of the corrections have negative values, they should also be shown in JPK_VAT with a "minus" sign.

When submitting a correction, the field: "Purpose of submission" should be completed. As explained by the Ministry of Finance, we proceed as follows:

Case 1.

In 2017 or 2016, only the original file marked with the number "1" was submitted, and the first correction is made in 2018 on the new structure. When filling in the JPK_VAT correction, enter the number "2" in the "purpose of submission" field, and mark subsequent corrections for the same period as "3", "4", "5", etc.

Case 2.

In 2017 or in 2016, JPK_VAT was submitted with the filing purpose "1", then corrections were submitted with the filing purpose "2", and in 2018 we submit another correction for this period according to the new structure in 2018. When sending a JPK_VAT correction, enter "3" in the "purpose of submission" field (regardless of how many JPK_VAT corrections marked "2" were submitted in 2017). We mark subsequent corrections for the same period as "4", "5" etc.

Case 3.

The taxpayer submits the JPK_VAT correction for the settlement for 2018. When sending the JPK_VAT correction, enter "1" for the first correction in the "purpose of submission" field. We mark subsequent corrections for the same period as "2", "3", "4" etc.