From 1 October 2020, entrepreneurs who are active taxpayers are obliged to use the additional split payment procedure for specific sale and purchase transactions.
MPP (Mechanizm podzielnej platnosci - split payment) is a symbol used in the new JPK_VAT file with the declaration for all sales and purchase invoices documenting the transactions covered by the mandatory split payment.
Pursuant to art. 108a (1a) of the Law on VAT, the obligation to make payments using split payment occurs provided that the following conditions are met:
- a VAT payer (active or inactive) has received an invoice with the indicated VAT amount or transfers all or part of the payment before the goods are delivered or the service is provided;
- the invoice received documents the purchase of goods or services listed in Annex 15 to the Law on VAT (in whole or in part) or the purchase of these goods or services - the amount paid before the delivery of the goods or service is provided;
- the total amount due on this invoice exceeds PLN 15,000 gross or this amount exceeds all or part of the payment before delivery of the goods or execution of the service, documented with an advance invoice.
Obligations of the seller and the buyer in the event of a transaction covered by the mandatory split payment:
- On the part of the seller - the obligation to mark the invoice with the words: "mechanizm podzielnej platnosci" and the obligation to accept payments from the buyer using this procedure,
- On the part of the buyer - the obligation to pay the amount due using the split payment.
For tax security reasons, many suppliers and service providers choose to mark all sales invoices with the words "mechanizm podzielnej platnosci". The possibility of accepting this simplification is justified in the tax clarifications of the Ministry of Finance of 23 December 2019 on split payment.
Buyers often choose to make payments using split payment for all invoices, so even those for which there is no obligation to apply the split payment.
The new JPK_V7 from 1 October 2020 requires VAT payers to mark with the "MPP" symbol only those sales transactions for which the use of split payment is mandatory, regardless of the note on the invoice and the method of payment for the invoice. For incorrect marking of the transaction (in case of failure to submit an adequate correction within 14 days from the date of delivery of the request in this regard by the responsible tax office manager), a penalty of 500 PLN may be imposed for each error.