Collective credit note

In the course of business, it may turn out that the entrepreneur will be required to issue a correcting invoice. There can be many reasons for the correction, but it should be noted that the provisions limit the situations in which such a document may be drawn up. What if several sales invoices for the same contractor need to be corrected? Is it necessary to issue a correcting invoice for each of them separately, or is it possible to issue one, common for all documents?

Collective correction invoice - when it can be issued

In accordance with par. 13 and 14 of the Regulation on issuing invoices, a corrective invoice may be drawn up in the case of:

• granting a discount after issuing the document,
• increasing the price - increasing the receivables,
• mistakes in the amount or rate of VAT,
• mistakes in the price,
• mistakes in another item of the issued invoice (e.g. the quantity of goods / services sold or the data concerning the parties to the transaction).

In the above-mentioned However, the provision did not provide information on the possibility (or lack thereof) of issuing one corrective invoice for several sales documents.

Correction invoice from January 2013

From January 2013, changes were made to the rules for issuing corrective invoices. Entrepreneurs drawing up such a document are exempt from the obligation to enter the amounts from the original invoice on the correction - now it is enough to include only the corrected amounts (i.e. those with changed values).

This provision is conducive to issuing corrective invoices with many items and collective correcting invoices (the need to include less information makes it easier to issue such documents). What does this mean in practice? One correction may correct several or even several dozen previously issued documents. The regulation of the Ministry of Finance regulates the issue of issuing collective corrections in the event of granting a discount, referred to in par. 13 sec. 3: "if the taxpayer grants a discount with regard to all supplies of goods or services made to one recipient in a given period, the correcting invoice should contain:

• sequential number and date of issue,
• data specified in par. 5 sec. 1 point 3 and 4 (i.e. the names and surnames or names of the taxpayer and the buyer of the goods or services and their addresses and the number by which the taxpayer is identified for the tax),
• the period to which the discount is granted,
• the amount of the discount granted and the amount of reduction of output tax ”.

There are no regulations regarding the possibility of issuing collective corrective invoices in situations other than granting a discount. However, this issue was often raised in individual interpretations, in which the tax authorities expressed a positive opinion on the possibility of issuing collective corrective invoices also in other situations (after meeting certain conditions, e.g. an individual ruling issued by the Director of the Tax Chamber in Poznań of June 30, 2010. , reference number ILPP1 / 443-404 / 10-7 / AW).

Conditions to be met by the collective correction invoice

In order for the collective correction to be considered correct, it must meet the requirements of the above-mentioned of the regulation and contain all the necessary elements specified therein. It is, among others, o specification of all the numbers of original invoices to which it relates, so that it is possible to unambiguously assign the corrected items or amounts to individual original invoices.

Furthermore, there is no law prohibiting the issuance of blanket corrections on invoices that are more than one month old. Collective adjustments may apply to sales for one contractor, e.g. for the entire year.

Correction invoices in 2014

From 1 January 2014, information on the rules for issuing corrective invoices will be included in the amended provisions of the VAT Act. Pursuant to Art. 106j paragraph. 1, the entrepreneur will be able to draw up such a document when, after issuing the invoice:

• discount was granted,
• discounts and price reductions were granted,
• goods and packaging have been returned,
• all or part of the payment to the buyer has been refunded,
• the price has been increased or there has been an error in the price, rate, tax amount or any other item in the invoice.

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In addition, paragraph 3 above of the article indicates that in the event that the entrepreneur grants a discount or price reduction in relation to all deliveries of goods or services made or provided to one recipient in a given period, the corrective invoice should contain the data necessary on such a document, as specified in Art. 106j paragraph. 2, i.e.

• the words CORRECTING INVOICE or CORRECTION,
• sequential number and date of issue,
• data contained in the invoice to which the correcting invoice relates (specified in Article 106e (1) points 1-6 and the name or type of goods or services covered by the correction),
• the reason for the correction,
• if the correction affects a change in the tax base or the amount of tax due - the amount of the tax base correction or the amount of the correction of tax due, respectively, broken down into amounts relating to individual tax rates and tax-exempt sales,
• in cases other than those indicated in the above point - the correct content of the corrected items,

and additionally:

• indication of the period to which the discount or rebate is granted,
• may not contain the data specified in art. 106e paragraph. 1 points 5 and 6 (NIP of the buyer and the date of the delivery or completion of the delivery of goods or the performance of the service) and the name (type) of goods or services covered by the correction.

Therefore, as you can see, the data that will have to be included in the correcting invoice will change. However, in the new regulations, the issue of issuing collective corrections has been regulated in a similar way to the current regulations, therefore it can be concluded that also after the entry into force of the amended VAT Act and the withdrawal of the invoice regulation, nothing will change with regard to the possibility of issuing collective corrections.