Amendments to the Goods and Services Tax Act – the whitelist of VAT payers – have been in force since 1 September 2019.

The whitelist is an electronic register of entities:

• which have been registered as VAT payers,
• which have not been registered as VAT payers or have been removed from the register of VAT payers,
• which have been re-registered as VAT payers,

along with their statuses, tax identification numbers (NIP), statistical numbers (REGON) and bank account numbers.

Collect (virtual) accounts

All banks operating in Poland must confirm the numbers of settlement accounts of their clients and the “masks” linked to those accounts used to generate collect (virtual) accounts with the IT System of the National Clearing House (STIR).

You can check your counterparties’ accounts in the register of VAT payers available on the BIP page (whitelist). If you search by NIP, REGON or name, you will see a list of settlement accounts of the given entity. You will not see a list of virtual accounts.

For some VAT payers, an additional comment may be displayed in the entity’s label shown in the browser under the list of settlement accounts (which are marked blue on both sides). The message, reading: “The entity may hold other bank accounts linked to the accounts displayed on the list,” marked orange on both sides, means that the list includes virtual account numbers which are not displayed in the entity’s label. To find such an account in the register, you need to enter a specific virtual account number.

After you enter a specific collect (virtual) account number linked to an entity’s settlement account in the browser, you will be informed if the account in question is included in the VAT register.
This applies to all collect (virtual) accounts of all banks. You do not need to confirm collect account numbers with banks. The search result obtained after you typed a specific account number to check if it was on the whitelist constitutes sufficient confirmation.

Assignment accounts

Assignment accounts related to assignment agreements and repayment accounts stipulated in agreements based on receivables purchase are not included on the whitelist, because they are not settlement accounts within the meaning of Article 49 (1) of the Banking Law Act. Assignment agreements and agreements based on receivables purchase remain in force.

The Polish Bank Association has published an announcement concerning the whitelist of payers and information for businesses on how to check counterparties’ accounts on its website.
If you have any doubts or questions concerning the whitelist, send them to WykazPodatnikow@mf.gov.pl.

We invite you to read the announcement.

Entry into force of sanctions

In accordance with Article 14 of the Act of 12 April 2019 (Journal of Laws, item 1018, the so-called Whitelist Act), Articles 2, 3, 5, and 10 will enter into force on 1 January 2020.

Articles 2, 3 and 5 of the Whitelist Act concern amendments to the Personal Income Tax Act, Corporate Income Tax Act and the Tax Ordinance Act and specify the consequences to be faced by a tax payer who sends a payment to an account outside the whitelist.

The Act provides for a transitional period expiring on 31 December 2019 during which no sanctions will be imposed on tax payers who send payments to accounts outside the whitelist.