White List and Split Payment in Poland: Rules for Paying Suppliers

The Polish VAT White List is an electronic register that allows a payer to verify whether a supplier is registered for VAT and whether the supplier’s bank account has been reported to the tax authorities. Together with the split payment mechanism, it is a key control point for businesses making payments to Polish suppliers.

These rules matter particularly where the value of a business-to-business transaction exceeds PLN 15,000. An incorrect payment route may affect tax deductibility, create VAT liability exposure and cause operational difficulties during a tax audit. The precise consequences depend on the transaction, the supplier’s VAT status and the payment method used.

White list VAT Poland: what the register shows

The White List, formally the List of VAT Taxpayers, is maintained by the Head of the National Revenue Administration. It includes, among other information, the VAT status of a business and the numbers of business settlement accounts reported by VAT taxpayers. The legal basis is Article 96b of the Polish VAT Act [1].

A purchaser should verify the supplier’s account before ordering a transfer. The relevant date is generally the date on which the transfer order is submitted, not necessarily the date on which the funds leave the purchaser’s bank account.

For internal control purposes, the business should retain evidence of the search result. This may include a PDF confirmation, a screenshot or an electronic record showing the supplier’s tax identification number, account number, date and time of verification.

Payments over PLN 15,000 in Poland: the basic rule

Article 19 of the Polish Entrepreneurs’ Law requires payments to be made through a payment account where both parties are entrepreneurs and the one-time transaction value exceeds PLN 15,000, regardless of the number of resulting payments [2]. The threshold concerns the gross transaction value.

Where a payment covered by this rule is made to an account not included on the White List, the payer may face income tax consequences. Under Article 15d of the Corporate Income Tax Act and Article 22p of the Personal Income Tax Act, the expense may not be tax deductible to the extent paid to an unverified account [3][4].

There is also a separate VAT risk. Article 117ba of the Tax Ordinance may impose joint and several liability on the purchaser for the supplier’s unpaid VAT relating to the transaction, subject to statutory protections [5]. This exposure is relevant where the supplier fails to account for output VAT.

Whitelist bank account verification Poland: practical process

Verification should be embedded in the accounts payable process rather than performed only for unusual transactions. A practical approach includes the following steps:

1. Confirm the supplier’s legal name and Polish tax identification number, known as NIP.
2. Check the supplier’s VAT status and account number in the White List on the transfer-order date.
3. Compare the verified account with the account shown on the invoice and in the supplier master data.
4. Retain verification evidence in the payment file.
5. Escalate discrepancies before payment, especially where the PLN 15,000 threshold is exceeded.

Verification is also advisable below PLN 15,000. Although the statutory income tax consequences described above are linked to transactions covered by Article 19 of the Entrepreneurs’ Law, payments to incorrect accounts may still create fraud, invoice-payment and compliance risks.

Three exceptions and safeguards for an account outside the White List

Where a payment is directed to an account not displayed in the White List, three safeguards require particular attention.

1. ZAW-NR notification

The payer may file a ZAW-NR notification with the head of the tax office competent for the payer within seven days from the date the transfer order is submitted. The notification identifies the supplier, the account used and the payment details. Timely filing protects against the relevant income tax restriction and VAT liability consequences [3][4][5].

The deadline is short. Businesses should therefore avoid relying on post-payment corrections as a standard procedure. The notification should be supported by payment evidence and approval documentation.

2. Payment using the split payment mechanism

A payment made using the split payment mechanism, known in Poland as MPP, benefits from statutory protection. The payment is split between the supplier’s regular account and its dedicated VAT account. The VAT amount is transferred to the VAT account, while the net amount goes to the supplier’s settlement account.

For purposes of the White List sanctions, use of MPP may protect the payer even if the account is not listed, provided that the statutory conditions are met [3][4][5]. The payment instruction should clearly use the bank’s split-payment function and include the required invoice data.

3. Payment to a virtual account linked to a disclosed account

Some suppliers use virtual accounts to identify payments from individual customers. A virtual account may not appear as a separate account number in the White List. If bank verification confirms that it is linked to the supplier’s disclosed settlement account, the payment may be treated as made to a verified account. The payer should retain the bank or White List confirmation showing that link.

This issue is common in high-volume supply chains and shared-service payment structures. A business should not assume that every virtual account is compliant without technical confirmation.

Split payment mechanism Poland mandatory transactions

The split payment mechanism Poland mandatory rule applies where all statutory conditions are met: the transaction is between VAT taxpayers, the gross invoice value exceeds PLN 15,000, and the invoice covers at least one good or service listed in Annex No. 15 to the VAT Act [1]. The annex includes selected sensitive goods and services, including certain steel products, electronics, fuels and construction services.

Where MPP is mandatory, the supplier must include the wording “mechanizm podzielonej płatności” on the invoice. This is the MPP invoice marking required by Article 106e(1)(18a) of the VAT Act [1].

Failure to mark the invoice or use MPP may lead to a 30% additional VAT liability in circumstances specified in Articles 106e(12) and 108a(7) of the VAT Act. Liability may be avoided in specific cases, including where VAT is properly settled by the supplier. The outcome depends on the factual circumstances and the applicable statutory exception.

Business impact and internal controls

For international businesses, these rules should be addressed in onboarding procedures, procurement controls and ERP payment workflows. Supplier account changes should trigger renewed White List verification. The finance team should also receive clear instructions on when ZAW-NR filing is necessary and when MPP must be used.

This is informational material, not legal advice. For a transaction-specific review of supplier-payment controls in Poland, contact us at Lawyersinpoland.com by Kopeć & Zaborowski.

FAQ – White List and Split Payment in Poland: Rules for Paying Suppliers

Is White List verification mandatory for every payment in Poland?

Verification is most important for business transactions exceeding PLN 15,000, where payment is made to a supplier’s account. Below this threshold, statutory tax sanctions may not apply in the same manner, but verification remains a sound compliance measure.

What is the ZAW-NR notification deadline?

ZAW-NR should be filed within seven days from the date on which the transfer order is submitted. Late filing may not provide the intended protection.

Does split payment always have to be used for invoices above PLN 15,000?

No. Mandatory MPP applies only if the invoice exceeds PLN 15,000 gross and includes goods or services listed in Annex No. 15 to the VAT Act, assuming the other statutory conditions are fulfilled.

What does “mechanizm podzielonej płatności” on an invoice mean?

It is mandatory invoice wording informing the buyer that payment should be made using the split payment mechanism. It is required in transactions covered by mandatory MPP rules.

Can an expense be tax deductible if paid to an account outside the White List?

It may be possible where the payer files ZAW-NR on time or makes the payment using MPP. The assessment depends on the transaction and the applicable income tax provisions.

Are virtual accounts visible on the Polish VAT White List?

Virtual accounts may not be displayed separately. The payer should obtain confirmation that the virtual account is linked to the supplier’s disclosed settlement account and keep that confirmation in the payment records.

Bibliography

• [1] Act of 11 March 2004 on Goods and Services Tax, in particular Articles 96b, 106e and 108a, and Annex No. 15.

• [2] Act of 6 March 2018 – Entrepreneurs’ Law, Article 19.

• [3] Act of 15 February 1992 on Corporate Income Tax, Article 15d.

• [4] Act of 26 July 1991 on Personal Income Tax, Article 22p.

• [5] Act of 29 August 1997 – Tax Ordinance, Article 117ba.

Ministry of Finance, “Explanations on the list of VAT taxpayers,” official guidance on the White List and account verification.