Poland’s Standard Audit File for Tax Effective as of July 1

A Standard Audit File for Tax (SAF-T) became effective in Poland on July 1. The relevant provisions were passed as amendments to the 1997 Tax Code on September 10, 2015, and additional changes and a detailed time schedule for the implementation of the SAF-T for particular groups of taxpayers were introduced on May 13 in amendments to the 1997 Tax Code.

Poland is gradually implementing the new fully electronic reporting system, first for VAT reporting and later, for other reporting elements, specifically:

• accounting books;
• bank account statements;
• storage reporting;
• purchase and sale VAT reporting;
• VAT invoices;
• reporting of revenue and expense records for tax purposes; and
• revenue reporting.

The electronic reporting will take place in XML format, automatically on a monthly basis, for purchase and sale VAT reporting and upon request for other reporting elements.The reports must be filed (submitted electronically) to the Ministry of Finance.

The general reporting obligations upon request are to be implemented in two stages: large businesses from July 1, 2016, and micro-, small, and medium-size businesses from July 1, 2018.The monthly VAT reporting obligation will be implemented in three stages: large businesses from July 1, 2016; small and medium-size businesses from January 1, 2017; and microbusinesses from January 1, 2018.

For purposes of the SAF-T regime, microbusinesses are defined as those that employ, on an annual basis, fewer than 10 employees and that have sales or balance sheet assets of €2 million or less. Small businesses employ, on an annual basis, fewer than 50 employees and have sales or balance sheet assets of €10 million or less, and medium-size businesses employ, on an annual basis, fewer than 250 employees and have sales of €50 million or less or balance sheet assets of €43 million or less. Business entities exceeding those figures are considered large.

The main purpose of the SAF-T, which has been recommended by the OECD and has already been implemented by a number of European countries, is to eliminate barriers in electronic data reporting, reducing the administrative burden and costs of audits for both tax authorities and taxpayers, and speeding up tax audits.