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Obligation to send the Uniform Control File for certain entities as of 1 July 2016

2016-04-28

Starting as of 1 July 2016, the amendment of the Tax Regulations will impose the obligation to send to tax authorities information originated from tax ledgers and accounting records via means of electronic communication or on data carriers as the Uniform Control File (UCF). The aim of implementing UCF is to shorten the time of control activities conducted by tax authorities and to ease their nuisance. Information obtained in this way by a tax authority may allow, in situations where there are no doubts, abandoning a standard control.

Entities required to use the Uniform Control File as of 1 July 2016 will be, in particular, large enterprises, i.e. entities with turnover in excess of EUR 50 million and employment over 250 persons. However, the above obligation will be in future extended to cover also other entities. After 30 July 2018 also small and medium enterprises will be required to use the Uniform Control File.

UCF is to unify data received by tax authorities, which will enable them, among others, to make comparative analysis of entities. Unification of files provided to tax authorities will be ensured by uniform XML format (according to OECD SAFT 2.0 standard) of tax books and accounting records. When summoned by a tax authority, the taxpayer will be obligated to provide the required information via a portal available on the website of the Ministry of Finance or on an external carrier  (DVD disc, pendrive).

Information which should be included in UCF are classified under 7 structures. The website of the Ministry of Finance presents the final version of uniform control files, detailing 7 structures i.e.

  • structure 1:        Accounting books,
  • structure 2:        Bank account statement,
  • structure 3:        Warehouse,
  • structure 4:        VAT purchase and sale records,
  • structure 5:        VAT invoices,
  • structure 6:        Revenue and expense ledger (Podatkowa księga przychodów i rozchodów),
  • structure 7:    Journals for recorded revenue tax purposes (Ewidencja przychodów opodatkowanych zryczałtowanych podatkiem od przychodów ewidencjonowanych).

Each of the above structures should contain strictly defined information. The structure of Accounting books should contain the following information:

  • trial balance,
  • general ledger balances,
  • general and subsidiary ledger entries.

The structure used for reporting balances of Bank account statement should contain detailed entries (lines) from a bank account statement for accounts kept by taxpayers.

The structure of Warehouse should contain information about warehouse movements i.e.:

  • items received from outside the warehouse,
  • items released outside the warehouse,
  • internal movements and relocations within the warehouse.

The structure of VAT purchase and sale records reflects in fact the fields of VAT-7 return. It contains information about transactions entered to the records kept for the purpose of VAT settlement. What is important, data contents in those records should be consistent with the VAT return for the same period.

The structure of VAT invoices is used to report information about sales, corrective, prepayment invoices and other documents equal to VAT invoice. At this level, the structure presents a number of optional information the reporting of which will depend on whether there were any transactions of given type.

Each of UCF level includes in addition the Heading where identification data of the reporting entity, date of preparing the file and period covered by the file (from…to) should be stated.

According to the Ministry of Finance, the amendment of the Tax Regulations imposing on taxpayers the reporting obligation upon summons of the tax authority using data provided as Uniform Control File is to facilitate verification activities and controls conducted by tax authorities. On the other hand,  we cannot help but notice that it is another obligation imposed on taxpayers requiring additional administrative work, which may have an impact on the costs of pursued activities.