The Ministry of Finance has made available a description of the API programming interface of the List of VAT taxpayers, i.e. a list of registered, unregistered, deleted and restored entities from the VAT register. The shared API interface is currently in the testing phase and, according to the Ministry of Finance, it may still change. The final API specification and test environment address will be made available by August 22, 2019.

Currently, VAT payers can be checked for their status manually (whether they are an active VAT payer, an exempt VAT payer, or an entity not registered as a VAT payer) in the search engine on the Tax Portal of the Ministry of Finance or automatically and in a mass manner from the libraries and tools provided by the portal.

What information will be available or verified in the white list of VAT taxpayers?

  • Confirmation of the contractor's bank account number – functionality now available, we offer access from programming libraries, JPK VAT application and add-in for MS Excel
  • Confirmation whether the contractor is an active VAT payer – functionality already provided by
  • Obtaining complete information about a given company, its headquarters and people representing it.
  • Obtaining the contractor's complete VAT tax history (date of refusal to register, deletion from the register or reinstatement as a VAT payer) along with the legal basis for these decisions.

On the website, we first plan to provide our customers with functionality related to confirming contractors' bank account numbers. The libraries and applications available on the portal will return exactly the same information as the MF API, i.e.:

  • YES/NO – short information indicating that a given account is or is not assigned to the verified contractor (on a given day),
  • requestId - i.e. an electronic key that confirms the execution of the query (what entity identifier was asked about, the date on which the answer was given and the date of submitting the query).

All this information will be stored in the system for evidentiary purposes, so that each of our clients can be sure that they have exercised the required diligence when verifying their contractor.

What data will be available to download from the register of the white list of VAT taxpayers?

Based on the information provided by the Ministry of Finance, it can be assumed that this will be the following data:

  • company name or name and surname of the entrepreneur;
  • the number by which the entity was identified for tax purposes, if such a number was assigned;
  • entity status:
    • in respect of whom registration has not been made or who has been deleted from the register as a VAT payer,
    • registered as an "active VAT payer" or "exempt VAT payer", including an entity whose registration has been restored;
  • REGON identification number, if assigned;
  • PESEL number, if the entity has one;
  • number in the National Court Register, if assigned;
  • registered office address - in the case of an entity that is not a natural person;
  • address of a permanent place of business or address of the place of residence, if there is no permanent place of business - in relation to a natural person;
  • names and surnames of persons constituting the body authorized to represent the entity and their tax identification numbers or PESEL numbers;
  • names and surnames of proxies and their tax identification numbers or PESEL numbers;
  • name and surname or business name (name) of the partner and his tax identification number or PESEL number;
  • date of registration, refusal to register or deletion from the register and restoration of registration as a VAT payer;
  • legal basis for refusal to register, deletion from the register and reinstatement of registration as a VAT payer, respectively;
  • numbers of bank accounts or accounts at the cooperative savings and credit union of which the company is a member, opened in connection with the business activity conducted - indicated in the identification application or update application.

What are the sanctions for making a transfer to a contractor's bank account other than the one on the white list of VAT payers?

At the beginning of 2020, if an amount exceeding PLN 15,000 is sent to the contractor to a bank account other than the one provided in the list, then:

  • it will not be possible to include in tax-deductible costs the amount in which the payment exceeds PLN 15,000. The number of transactions into which the payment resulting from a given invoice will be divided will not matter,
  • the entity sending the payment will be held jointly and severally liable with its contractor for tax arrears if the contractor fails to pay the VAT due on the transaction.

The Ministry of Finance plans to update taxpayers' data once a day, on every working day. Therefore, in order to avoid the above-mentioned consequences, you should check your contractor's bank account numbers on the same day when the transfer is planned to be made.

Source: Ministry of Finance

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