34 (129) 2018
Download PDF-version

Finance & Financial Services

Standard Audit File – Invoice, on request

By Bogdan Zatorski, Tax Digitisation Expert at Sage
Header b zatorski


All VAT payers are already sending the Standard Audit Files for Tax ('JPK' in Polish) to the Ministry of Finance's servers.

This means that the MF is now effectively gathering information about all invoices issued by Polish taxpayers. Based on these files, the IT system of the KAS (national treasury administration) compares purchase invoices and the VAT deducted by taxpayers with the output VAT shown by sellers in their sale invoices.

In the event of the discovery of discrepancies, taxpayers are requested to explain the differences in the transactions compared. The MF has at its disposal a very precise tool for verifying possible discrepancies in the form of another reporting structure –   the SAF-I (invoice).

Request for explanations – transaction details

The SAF-I structure is designed for presenting detailed data from sale invoices. The amount of data included in this file is incomparably greater than contained in the SAF-T. The SAF-I presents not only aggregate data but also individual items of the sale invoice with names of the goods and services, quantities, unit prices, rebates. For this reason, the data for inclusion in the file must be collected directly from the sales support program, and not from the financial-accounting program. Entities which do not keep sales records electronically (in a program) will not be able to generate this file. In such cases one should expect the traditional form of audit of fiscal inconsistencies in the form of a visit by a representative of the KAS.

SAF_I only at KAS’s request

Taxpayers will prepare the SAF_I file only if requested to do so, usually in the course of a verification or audit procedure – in accordance with the provisions of the Tax Ordinance Act . The services verifying information request data covering a specific period – according to the sale date or invoices issue dates. The request may pertain to all sales or those carried out at the indicated branch. KAS also sets a time limit (in most cases seven days) for preparing and sending the file.

Protection period ends on 1 July 2018

According to the transitional provisions of the Tax Ordinance Act, providing for a gradual introduction of reporting obligations based on the standards audit files, the obligation to submit the SAF_I initially applied to the largest, and then to medium-sized enterprises. As of July 2018, every taxpayer issuing invoices using a computer will be obligated to provide SAF_Is at KAS’s request.

SAF_I causes problems to larger enterprises – beware!

Preparing data in the structure is not an easy task. So far, taxpayers have submitted as many detailed questions regarding this structure as in the case of the more universally used SAF_T. One should use the time left until July for testing the capabilities of the invoicing software. Remember also to update the programs to the latest version adapted by their makers to the handling of the SAF_I.

The Ministry of Finance has found 85,000 suspicious invoices using the SFA_T

According to the figures released by the Ministry of Finance in mid-March, almost all businesses (1,508,458, that is 94.5% of all VAT payers), submitted their SAF_T on time, by 26 February 2018.

Out of 1,703,271 files sent by businesses 76,534 were rejected. 88,163 taxpayers failed to discharge their tax obligation.

650 million invoices were analysed. After the preliminary verification, 85,000 of them were questioned by the tax authorities as potential “empty invoices”. This means that they will require detailed checks carried out by KAS, the national treasury administration. These 'empty invoices' were issued by 36,000 entities; the VAT from these invoices amounted to 105 million zlotys.

More in Finance & Financial Services:

Paving the two-way highway

By Bank Pekao S.A.


While people have been calling the world a global village for decades, and technology has further amplified this by providing us with information and contact at the touch of our fingers, financial cross-border markets don’t always live up to that promise.

Impact of Brexit on the European and Polish insurance market

by Beata Balas-Noszczyk, partner, Hogan Lovells in Poland, and Charles Rix, partner, Hogan Lovells in the UK


The UK is seen as the world’s leading insurance centre; London’s financial institutions have access to enormous amount of potential consumers, reflecting its economic potential.

Technology and regulation: making life easier for Polish exporters

by Jakub Makurat, country manager Poland, Ebury


The UK is one of the main trading partners for Polish exporters.

Trading between Poland and the UK? Get ready for Brexit

by Marcin Majewski, manager, PwC


Despite hopes or doubts, Brexit is seen to be inevitable; companies should start their preparations now. The biggest impact from the tax perspective will result from customs duties and VAT.