In accordance with the Act, split payment is obligatory in the case of the following transactions:
Split payment is mandatory in the case of goods and services listed in Appendix No. 15 to the Act. These include:
By default, the bank will open one VAT account for one entity. If we have several current accounts in one bank, it is allowed to open many VAT accounts at the client's request. However, we should be remembered that one current account must always be associated with only one VAT account.
VAT accounts can be interest bearing. It depends on the bank. However, this interest should not be less than the interest on the current account. It can also be higher. What is important: interest collected on the VAT account will be booked on the current account, not on the VAT account.
Yes. The customer can freely transfer funds between his own VAT accounts
(under the same banking agreement – in one bank).
In this case, please indicate in the transfer:
a) in the 'VAT amount' field - the amount of transferred VAT resources (for transfers between own VAT accounts, mandatory: gross amount = VAT amount),
b) in the 'Invoice number' field, enter 'przekazanie własne' (own transfer)
c) in the 'Tax identifier' field - unlike other SP transfers - own NIP or international IDC.
In the current solution, this is not possible. Only entities that have a bank account in PLN can use the split payment method.
WARNING! Split Payment is a method intended for mutual settlement of amounts resulting from VAT in PLN currency. This means that in the case of settlements, e.g. in EUR, there is a theoretical possibility of paying the VAT itself after conversion into PLN (in this case the payment for the net invoice can be made by traditional currency transfer and payment for the VAT itself by transfer in PLN in the SP mode.)
The VAT account does not need to be reported to the Tax Office.
Positive aspects of the use of SP accounts include:
The amendment of the VAT Act does not provide for additional criteria that must be met by the taxpayer to receive VAT refund within 25 days. The only condition is that the return has to be made to the VAT account, not to the current account.
On the bank statement, in case of booking the incoming SP transaction, in the first place, the gross transaction will be recorded (the full amount of the invoice). Then the funds in the amount of VAT (charge) will be transferred from the current account to the VAT account. In turn, when we make payments for invoices using the SP mechanism, in the first place the current account will be credited with the VAT amount indicated in the SP order (from VAT account). Then the full gross amount will be sent from the settlement account.
In the case of mistakes, you can always make corrective payments, referring to the same payment (referring to the same invoice number). Of course, such a correction must be made, depending on the nature of the error, by the sender or the recipient. For example, we can return a transfer to the payer with a request to re-pay with the correct data. You can also settle only the difference itself, e.g. refund overpaid VAT or ask the contractor to pay a shortage of VAT.
WARNING! The case of returns and corrections requires correct completion of the payer's identifier (NIP) field - in SP transfers we always provide the IDC / NIP of the party receiving the VAT (i.e. the counterparty's data).
It is not possible. A Split Payment transfer made to a personal account will be returned by the recipient's bank to the payer's bank. A necessary condition for the correct implementation of SP transactions is that the service provider always uses a company account (issued by him) on VAT invoices.
Split Payment can only be used in transactions carried out for other VAT payers and used to transfer VAT funds in PLN currency. Split Payment cannot be used in B2C transactions (see also answer to the point above).
Yes, they can. In line with the Act, a VAT invoice issuer may issue a summary invoice for a period of at least one day and not exceeding one month. The relevant period must be entered in the “Invoice number” field. Batch payments can be made for both transfers and direct debits.
For now, it is not possible to use this procedure in other forms of payment than a domestic transfer. Maybe this will change in the future.
You will not be able to use a split payment due to the receipt of a "pro forma invoice". According to art. 108a of the VAT Act, payments with the use of this mechanism can be made only if you have an invoice within the meaning of the VAT Act. "Pro forma invoice" does not meet this condition - it is only a document accepted in the course of trade, which serves to confirm the submission of an offer with a given content or confirmation of the order being accepted.
Yes, information on the VAT account and the VAT account balance will be available in the mBank CompanyNet, BRESOK and MutliCash systems.
Information on turnover and the VAT account balance will be available in the mBank CompanyNet, BRESOK and MutliCash systems as well as in the form of MT940 messages sent using SWIFT.
The opening of the VAT account will require that the ERP systems receive additional information on the balances of the opened VAT accounts. As in the case of other accounts, statement in the MT940 or information on turnover in the MT942 format will serve for this purpose.
Not for the electronic banking systems mBank CompanyNet, BRESOK and MultiCash. Based on the definitions of the accounts connected with the VAT account, we will automatically start sending the appropriate format of bank statements pertaining to the opened VAT account.
In the case of MT940 and MT942 as well as MT950 provided using SWIFT, such a request is to be submitted to the bank.
The VAT account will be maintained free of charge.
No, every user with access to new accounts will obtain access to the opened VAT accounts.
No, the authorisations to execute the new type of orders are connected with authorisations to execute domestic transfers or direct debits. Every user will automatically be authorised to make a given type of instructions.
No. For domestic transfers in form of split payments, the current domestic business partner base will be available. When entering a transfer, it will be possible to record in the base the business partner’s tax identification number NIP.
In the case of direct debits in form of split payments, the current base of direct debit payers will also be available.
Yes, to a small extent. In the import of orders it is enough to include new payment details (title field) in line with the new structure of the import of orders.
The new import structure in the pain.001.001.03 (ISO20022) format can be downloaded by clicking on this link: Structure of data import set in the pain.001.001.03 (ISO20022) format
The new import structure in the Elixir format can be downloaded by clicking on this link: Structure of data import export set in the ELIXIR format for mBank CompanyNet and BRESOK
In the turnover, there will be additional data in the payment title field, in line with the following structure:
/VAT/123,00/IDC/5260215088/INV/FV/2018/03/23/TXT/For telecommunications services, where:
/VAT/123,00/IDC/5260215088/INV/FV/2018/03/23/TXT/For telecommunications services, where:
Payments executed as split payments are to be identified based on the details of the field :86:.
Split payment is mandatory in the case of goods and services listed in Appendix No. 15 to the Act and in the case of transactions exceeding PLN 15,000.00 gross or its equivalent in another currency.
No. We do not have the right to verify it or to advise on tax matters. You will decide on the order amount and the VAT amount.
mBank