21 Dec Split payment and modifications in Microsoft Dynamics NAV

The mechanism of split payment will become binding for P on 1 July 2018.  The change of the act on the taxation of goods and services (Value Added Tax Act) that introduces the split payment mechanism entails the need for modifications in Microsoft Dynamics NAV.

What is split payment?

The essence of split payment is that the purchaser, while settling the payment of an invoice, will decide whether to pay the full (gross) amount to the supplier’s settlement account or split the payment by using the so-called “transfer message”. As a consequence, banks and credit unions will automatically split the payment and pay the net amount to the supplier’s bank account. The VAT amount will be paid to a special separate VAT account.

In the dedicated transfer message, the purchaser must indicate:

• an invoice no. (including prepayment invoices and credit memos),
• supplier’s VAT registration no.,
• gross amount,
• VAT amount.

Banks as well as credit unions will be obliged to open a VAT account for each settlement account. No separate agreement with the bank will be needed to open the account and banks will not be able to charge any fees or commissions for administering the account.

VAT accounts will be denominated in PLN and the supplier will be the owner of the funds located on the VAT accounts. However, he will be entitled to settle only those liabilities that arise from VAT regulations.

The VAT account could be used only to:

• pay VAT to the VAT account of another entity,
• return VAT to the VAT account in connection with issuing a credit memo,
• pay VAT or late payment interest to the account of the tax office,
• pay tax for the intra-Community acquisition of goods,
• pay VAT for the supply of goods/services,
• return the amount unduly received to the VAT account of the payer,
• transfer the amount to the other VAT account maintained by the same bank,
• transfer VAT amount to the budget entity’s account.

The split payment mechanism could be used on a voluntary basis, however, it may bring several benefits:

• the funds accumulated on the VAT account are not subject to court or administrative proceedings,
• in case the owner of the VAT account dies, VAT liabilities and late payment interest do not make up the estate,
• lack of penalties under the Article 105a (joint responsibility), the Article 112b (20% penalty) and the Article 112c (100% penalty) of the VAT Act, to the amount of VAT paid by using the split payment mechanism,
• lack of 150% penalty for the late payment interest (under the Article 56b of the General Tax Code) – to the amount of outstanding tax liability resulting from the submission of the declaration, in which the tax payer indicated that at least 95% of the input VAT amount results from received invoices with the input tax that were paid by using the split payment method,
• joint responsibility of the tax payer who received the payment is excluded, if the tax payer makes a payment to the supplier’s VAT account in the amount that is equal to the amount that he received into his own VAT account,
• if tax is fully paid from the VAT account at an earlier date, the tax payable can be reduced by the calculated amount. Consequently, the payable tax will be lower.

Planned modifications in Microsoft Dynamics NAV

Following the introduction of the split payment mechanism, modifications in Microsoft Dynamics NAV have been planned. After making required adjustments, it will be possible to generate reports that are necessary to prepare outgoing payments as well as payments made by using the E-banking module.

We would like to ensure you that we are constantly monitoring the works carried out on the draft act and that planned modifications will be implemented in due time and in the full scope required by the regulations. Please also note that more detailed information will be forwarded to you once the legislative work is completed and the act is finally adopted.