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Simplified invoice in JPK V7 file - how should it be shown?

The introduction of a new JPK file structure in the form of JPK_V7, which replaced the VAT declarations and JPK_VAT files sent so far, were informed by the Minister of Finance in 2019. The above changes also affected simplified invoices, which, in accordance with previous announcements, are shown in the JPK_V7 file. How and when the simplified invoice is shown in the JPK V7 file is explained below!

The new JPK_V7 structure is mandatory from October 1, 2020

The ordinance 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 introduced a new JPK file structure in the form of JPK_V7 and it is mandatory for VAT taxpayers active from October 1 2020. The new structure is to simplify the current reporting obligations by replacing the VAT declaration and JPK_VAT file with one JPK_V7 structure. However, the simplification of reporting obligations is not the only motive of the legislator, as the new SAF structure presents economic transactions made by taxpayers in a more detailed way, which influences their more effective control by tax authorities.

Detailed information on the new JPK file structure and the scope of information contained therein are described in the article: JPK V7M - from when will the changes in reporting apply to taxpayers?

Receipt as a simplified invoice

The introduction from January 1, 2020 of the obligation to show the buyer's NIP number on the fiscal receipt when the transaction concerns an entrepreneur, gave the term "simplified invoice"New meaning. Pursuant to the changes, a fiscal receipt that meets the conditions specified in Article 106e section 5 point 3 of the VAT Act, including:

the total amount due does not exceed PLN 450 or EUR 100,
the buyer's NIP (tax identification number) was indicated on the receipt.

If the above conditions are not met jointly, the received fiscal receipt does not constitute a simplified invoice, therefore the buyer, in order to include the cost in the KPiR and deduct VAT, must ask the seller to issue an invoice for the receipt. It should be noted that the seller may issue an invoice for the receipt only if the buyer's tax identification number is indicated on the receipt. Otherwise, the invoice for the receipt cannot be issued, and its issuance may result in the imposition of sanctions on the seller and the buyer.

Example 1.

The buyer asked company X to issue an invoice for the receipt, returning for this purpose the fiscal receipt issued on April 4, 2020. The receipt does not include the buyer's tax identification number (NIP) - is the seller obliged to issue a sales invoice in this case?

Due to the fact that the buyer's tax identification number was not indicated on the receipt, the seller cannot issue an invoice for the receipt.

Example 2.

The taxpayer purchased office supplies and received a fiscal receipt from the seller, on which his tax identification number was indicated. The receipt was issued for PLN 320 gross. Should the taxpayer, in order to document the cost incurred, ask the seller to issue an invoice for the receipt?

Due to the fact that the receipt includes the buyer's NIP number and that its value does not exceed PLN 450, it is a simplified invoice, on the basis of which the taxpayer can post the cost in the KPiR. In accordance with the above, it is not necessary to ask the seller to issue an invoice for the receipt.

The issue of the invoice for the receipt has been described in the article: NIP number on the receipt from January 1, 2020 - application in practice

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Simplified invoice in JPK V7

According to the information provided, whether a fiscal receipt is the basis for inclusion in the KPiR and VAT is determined by the scope of the data shown on it, such as the buyer's tax identification number and the transaction value below PLN 450 / EUR 100. If these conditions are met, the receipt is considered a simplified invoice. Pursuant to Art. 106e section 5 point 3 of the VAT Act, a simplified invoice - although it does not have the same scope of data as a standard invoice:

the date of issue;
a sequential number from one or more series that uniquely identifies the invoice;
the first and last names or names of the taxpayer and the buyer of goods or services and their addresses;
the number by which the taxpayer is identified for tax purposes;
the number by which the buyer of goods or services is identified for the purposes of tax or value added tax under which he received the goods or services;
the date on which the delivery of the goods or the service was completed or completed, or the date on which the payment was received, if such date is specified and differs from the date of the invoice;
name (type) of goods or services;
measures and quantity (number) of delivered goods or scope of services provided;
unit price of a good or service without the tax amount (net unit price);
the amount of any price rebates or reductions, including in the form of an early payment rebate, provided that they are not included in the net unit price;
value of the goods delivered or services performed covered by the transaction, excluding the tax amount (net sales value);
tax rates;
the sum of the net sales value, broken down into sales subject to individual tax rates and sales exempt from tax;
tax amounts on the sum of the net sales value, broken down into amounts related to individual tax rates;
total amounts due

- is treated as equal to it, which means that it should be shown in the new structure of the JPK_V7 file as a separate item, and not, as is the case with fiscal receipts, in the aggregate value based on a total periodic report from the cash register.

The above obliges taxpayers to include simplified invoices in a separate register, so that they are listed in VAT registers and in the JPK_V7 file. Thus, it obliges to reduce the value of sales recorded through the cash register by the value of simplified invoices, so as not to double the revenues.

The postponement of the validity date of the new JPK file to October 1, 2020 for all active VAT taxpayers also affected the changes in relation to the recording of the simplified invoice. Namely, in accordance with the provisions of the Ministry of Finance, the simplified invoice in the JPK_V7 file does not have to be presented until December 31, 2020, provided that it is included in the fiscal report.

Simplified invoice in the JPK V7 file and GTU codes

In the new JPK_V7 file, taxpayers are required, inter alia, to to designate certain goods and services in a special way - by assigning the invoice the appropriate GTU code (group of goods and services). GTU designations are used only by sellers who sell sensitive goods or services - then in the record part of the JPK_V7 file for the invoice documenting the sale of sensitive goods or services, they are required to select GTU. The groups of goods and services subject to marking have been divided into 13 groups and given numbers from GTU_01 to GTU_13. A detailed list is provided below:

GTU_01 - supplies of alcoholic beverages - ethyl alcohol, beer, wine, fermented beverages and intermediate products, as defined in the provisions on excise duty;
GTU_02 - delivery of goods referred to in art. 103 paragraph 5aa of the VAT Act;
GTU_03 - deliveries of heating oil within the meaning of the provisions on excise duty as well as lubricating oils and other oils;
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 VAT Act;
GTU_06 - deliveries of electronic devices and parts and materials therefor, exclusively specified in item 7-9, 59-63, 65, 66, 69 and 94-96 of Annex 15 to the VAT Act;
GTU_07 - deliveries of vehicles and specific car parts;
GTU_08 - deliveries of precious and non-precious metals - only specified in item 1-3 of Annex 12 to the Act and in item 12-25, 33-40, 45, 46, 56 and 78 of Annex 15 to the VAT Act;
GTU_09 - supply of drugs and medical devices - medicinal products, foodstuffs for particular nutritional uses and medical devices subject to the reporting obligation referred to in Art. 37av paragraph. 1 of the Pharmaceutical Law;
GTU_10 - deliveries of buildings, structures and land;
GTU_11 - provision of services for the transfer of greenhouse gas emission allowances referred to in the act on the greenhouse gas emission allowance trading scheme;
GTU_12 - providing consulting, accounting, legal, management, training, marketing, advertising, market and public opinion research services in the field of scientific research and development works;
GTU_13 - provision of transport services and warehouse management.

If the simplified invoice records the sale of a good or service subject to the GTU code marking obligation, apart from showing it separately in the JPK_V7 file, as is the case with standard sales invoices, the GTU designation should also be applied to it.