The white list — when to verify an account

For every payment above PLN 15,000 gross to an active VAT payer, you must check that the contractor's bank account appears on the VAT taxpayers list (white list) as at the day the transfer is ordered. The search tool and API are available from the Ministry of Finance; most business banking systems verify accounts automatically — make sure the feature is enabled and archives confirmations.

Consequences of paying outside the list

  • the expense is not tax-deductible (PIT and CIT),
  • joint and several liability for VAT unpaid by the contractor,
  • sanctions can be avoided by filing a ZAW-NR notification within 14 days of the transfer (one notification per contractor and account suffices),
  • paying via split payment also removes the sanctions, even if the account was not listed.

Mandatory split payment

The split payment mechanism is mandatory when the invoice exceeds PLN 15,000 gross and covers goods or services from Annex 15 to the VAT Act (construction works, scrap, electronics, fuels, car parts, among others). The invoice must bear the annotation "mechanizm podzielonej płatności". The seller is liable for a missing annotation; the buyer for skipping split payment (a sanction of 30% of the invoice VAT).

Funds in the VAT account

Funds accumulated in the VAT account can be used to pay VAT, PIT, CIT, ZUS, excise and customs duties, as well as VAT on purchase invoices. Excess funds can be released upon application — the standard processing time is 60 days.

Practical tips

  • enable automatic white-list verification in your banking and archive the query UUID,
  • in contracts with suppliers from sensitive industries, require invoices with the MPP annotation,
  • for instalments and set-offs the PLN 15k limit refers to the whole transaction, not a single transfer.

As part of our bookkeeping services we monitor the VAT status of our clients' contractors and handle ZAW-NR notifications whenever a transfer goes outside the list.