New regulations applicable to SAF-T (pl.:JPK VAT) will apply from 01.01.2022. It's an update of XML schema definition of SAF-T VAT. Therefore changes must be implemented in M3 by the end of year 2021. Until then SAF-T from 01.07.2021 to 31.12.2021 can be made in accordance to old regulations. Certainly VAT deadline in Poland is 25th day of next month, so there is some buffer for implementation. As always we recommend to install and test new system update before legal change is due, that is before 1st of January 2022.
Below please find major changes which could reflect the way, how Your company reports VAT.
1. Removing the “MPP” tag (en.: split payment) - Tag will be not used in declaration any more, both from receivables and payables sides. Nevertheless tag “MPP” still should be used on invoices and in payments which simultaneously are listed in the Annex no.15th to the VAT Act and overcome total gross amount 15.000 zł.
Therefore tag “MPP” should be removed only from SAF-T declaration but leave the definitions in CMS880 since these tagging might be needed for old reports to be issued for year 2021 and earlier.
2. Changes in tags “SW” and “EE” – These tags related will be replaced with new term “WSTO_EE” (en.: Intra-Community remote sales of goods).
This change consider applies usually to e-commerce sales and services, usually won't be implemented by manufacturers or distributors. Key definition of sales, which should trigger WSTO_EE is that the delivery is made to i.e. a customer who is not a payer of VAT.
3. Introduction of new tag “IED” (Electronic Supplier Interface) - New term refers to deliveries of goods from Art. 7a paragraph 1 and 2.
This change consider also e-commerce sales and services. Usually won't be implemented by manufacturers or distributors.
4. Bad Debts Handling - Regarding adjustments made due to Art. 89a paragraph 1 and 4 of the VAT Act there will be obligation to present in SAF-T declaration the date of payment expire or the date of the payment. This change refers to collection of substantiated receivables.
New regulation require adding new fields for bad debts documents: due date, payment date. As of end of October 2021, Infor is awaiting business case before it will implement this tag. Additionally, if it happens in rare case Standard Audit File xml file may be edited manually.
6. The introduction of new position in SAF-T structure P_660 - Changes in accordance to transactions where the taxpayer facilitated through an electronic interface the delivery of goods and provision of services specified in art. 109b paragraph 4 of the VAT Act.
As of the end of October 2021, Infor is awaiting business case before it will implement this tag.
7. The introduction of new position in SAF-T structure P_540, P_560 – Change refers to Tax Refund within 15 and 40 days on taxpayer settlement account.
New definitions should be added to TXS035. If there is a definition, add “1” to the tag, else “Brak” (Similar to number 955 for P_56 KB 2186238 / JT-1558121)
8. Creation of new code “XI” for Northern Ireland in the SAF-T structure – New code should replace the old “GB” code. In our opinion country codes in CRS045 + customer country parameters should be adjusted.
In order to install new features companies working with Infor M3 should download and install all current fixes applicable to AAS381, AAS380, CMS880, CMS881
Authors: Patrycja Morawiecka, pmor@lightning-erp.com
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