Bulk invoices do not always bring tax benefits


Collective invoices - what is it?

The new legal regulations in force from the beginning of 2013 allow for the issuing of collective invoices, which results directly from § 9 para. 3 of the regulation of the Minister of Finance, inter alia, on the issue of invoices, which reads as follows:

The invoice may document several separate deliveries of goods or services made during the month, if it is issued no later than the last day of the month in which the goods were issued or the service was performed.

This invoice contains the data of an ordinary invoice, in accordance with § 5 of the Regulation. However, the problem may arise when determining the date of sale (the date when delivery of goods or service was completed or completed). In this case, enter the date of the last delivery that is documented by this invoice.

It is not possible to shift the tax obligation in the case of a collective invoice

In the case of collective invoices, the tax obligation under VAT arises on the date of issuing the invoice, i.e. on the last day of a given month at the latest.

This is a different situation, which does not allow for the shift of the tax obligation, which is possible in the case of ordinary sales invoices, because, according to the regulations, the invoice is issued no later than the 7th day from the date of delivery of the goods or provision of the service.

Then, in the case of a sale that takes place at the end of a given month, we can shift the tax obligation to the next month by issuing an invoice at the beginning of this next month.


The entrepreneur made two deliveries during the month of April, i.e .: 09/04 and 25/04. If he documents them with a collective invoice issued on the last day of April, then the tax obligation arises for both deliveries in April.

The entrepreneur made two deliveries during the month of April, i.e .: 09/04 and 25/04. He issued the invoices on April 12 and May 1, respectively (with the relevant deadline of 7 days). Then the tax obligation for the first invoice arises in April, and for the second - in May. And this is how they will be included in VAT returns.

Collective invoices and construction and transport services

In the case of transport and construction services, there is a special date when a tax obligation arises under VAT. Pursuant to Art. 19 paragraph 13 point 2a and point 2d of the VAT Act:

The tax obligation arises upon receipt of all or part of the payment, but not later than on the 30th day from the date of the provision of passenger and cargo transport services by rail, car fleet, sea-going ships, inland and coastal transport, ferries, airplanes and helicopters, and construction services. or construction and assembly.

There is a high probability that the tax obligation for each of the services provided in a given month arises in different settlement periods, despite the fact that they will be documented with one invoice.


On one collective invoice, the entrepreneur documented the services performed in a given month for the contractor X. These services were actually performed on 01/05 and 28/05. Payment will be made in July.

The tax obligation on the basis of VAT for the first of them will arise on May 31, 2013 (on the 30th day of the service), so it should be settled in the VAT declaration for May. However, for the latter, the 30th day falls in June, so the tax obligation will also arise in June.

Collective invoice and foreign currency

Collective invoices issued in a foreign currency, like any other, should be converted into Polish zlotys for tax purposes.

With this type of invoices, Art. 31a paragraph. 1 of the Value Added Tax Act, which says:

If the amounts used to determine the tax base are specified in a foreign currency, conversion into zlotys is made at the average exchange rate of a given foreign currency announced by the National Bank of Poland on the last business day preceding the day when the tax obligation arises. The taxpayer may choose the method of converting these amounts into zlotys according to the last exchange rate published by the European Central Bank on the last day preceding the day when the tax obligation arises; in that case, currencies other than the euro shall be converted using each's exchange rate against the euro.

It is worth noting that the above applies to the conversion for VAT purposes. However, for income tax purposes, a separate conversion should be made according to the average NBP exchange rate from the last business day preceding the day of obtaining income. (Article 11a (1) of the PIT Act).