Rounding in VAT registers sent electronically
In the light of the explanations of the Ministry of Finance, the purpose of SAF-T is to enable taxpayers to provide information to tax authorities in an electronic form, allowing them to shorten the time of activities, reduce their nuisance and, as a result, reduce their costs. In clear cases, this form of disclosing information will allow you to withdraw from control. JPK covers not only the settlement of tax on goods and services, but also other taxes and the broadly understood verification of accounting books and tax records. What rounding in VAT registers will be possible in the submitted declarations?
Who has to submit JPK VAT?
From January 1, 2018, all VAT taxpayers send the VAT register in electronic form. 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. Thus, from the new year, each VAT payer must send the VAT register in the form of SAF-T every month, regardless of the method of settling this tax.
A small taxpayer chose the method of settling VAT for the quarter. In the light of the new legal regulations, from January 1, 2018, it will be obliged to send VAT registers in the electronic form of SAF-T. Despite choosing the quarterly billing method, you will need to upload your records every month. The above will result in the necessity to keep VAT records on an ongoing basis.
What is JPK_VAT to reflect? - explanations from the Ministry of Finance
Deputy director of the Ministry of Finance Tax Collection, Zbigniew Wiliński, explained that:
"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 a translation of records into a certain scheme that functions in a uniform manner among all taxpayers. "
In the light of the above explanations, it should be considered that the submitted purchase and sales records must reflect the sales and purchase records kept.
Pursuant to Article 109 (3) of the Act of March 11, 2004 on tax on goods and services (Journal of Laws of 2017, item 1221), hereinafter referred to as the "VAT Act", active VAT taxpayers are required to keep records containing data used for the correct preparation of a tax declaration, i.e. the amounts specified in Article 90, the data necessary to determine the subject and base of taxation, the amount of tax due, the amount of input tax reducing the amount of tax due and the amount of tax to be paid to the tax office or the amount to be returned ex officio. The VAT register includes data resulting from both sales and purchase invoices. It should be remembered here that the amounts on invoices are rounded to the nearest penny. The above invoices, as we have shown above, are the basis for entries in the VAT register. The amounts from invoices in rounding are included in these records.
Rounding in VAT registers - VAT-7 declaration
Pursuant to Art. 63 § 1 of the Tax Ordinance of August 29, 1997 (Journal of Laws of 2017, item 201, as amended), hereinafter referred to as the "Tax Ordinance", tax bases, tax amounts, late payment interest, prolongation fees, the interest rate on overpayments and remuneration due to payers and collectors are rounded to full zlotys in such a way that the endings of amounts of less than 50 groszy are omitted, and the endings of amounts of 50 and more groszy are increased to full zlotys, subject to § 1a and 2. In in the light of the regulation of the Minister of Development and Finance of 27 December 2016 on specimen declarations for tax on goods and services (Journal of Laws of 2016, item 2273) and explanations regarding VAT-7 and VAT-7K declarations Declaration items are rounded to full zlotys in such a way that the endings of amounts amounting to less than 50 groszy are omitted, and the endings of amounts amounting to 50 groszes or more are increased to full zlotys.
Possible discrepancies between the VAT return and registers
Considering the above, there may be slight discrepancies when transferring the data contained in the summary of the sales and purchases register to the VAT-7 declaration. The tax base is rounded in accordance with the above-mentioned art. 63 § 1 of the Tax Ordinance. Thus, it may happen that the tax base shown in the VAT register (and then transferred to the VAT-7 declaration rounded to full zloty) multiplied by the tax rate will differ from the tax amount shown in the register.
Rounding in JPK
In the information brochure on the JPK_VAT structure posted on the website www.mf.gov.pl, in the "Questions and answers" section, we read:
“1. Are the amounts in JPK_VAT to be rounded in accordance with the rules for the declaration?
Amounts in JPK_VAT are reported in PLN and grosze, without rounding.
To sum up, in the light of the explanations of the Ministry of Finance, the amounts shown in SAF-T are not subject to rounding referred to in art. 63 § 1 of the Tax Ordinance. Thus, the data from VAT registers provided in the form of SAF-T may slightly differ from the data shown in the VAT-7 declaration. The above differences - taking into account that they only concern rounding - will be insignificant.