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What is the whitelist of VAT payers? How to whitelist your company?

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by ​Przemysław Trzaska

28 November 2023


The whitelist of taxpayers is a public record which supports transaction transparency.

In this article you will learn:


What the whitelist of VAT payers is

The Ministry of Finance introduced the whitelist of VAT payers in September 2019. It is a public list of enterprises – VAT-registered taxpayers, non-registered taxpayers, taxpayers deleted from and reinstated in the VAT register – designed to help businesses check their business partners. The whitelist of VAT payers is kept by the Head of the National Revenue Administration (NRA) and is designed to ensure transaction transparency and prevent financial frauds, e.g. missing trader frauds. The list is available online on government websites.

Why it is worth being whitelisted

The whitelist lets you easily and quickly check if your business partner is a VAT-registered taxpayer. The whitelist also shows why a company has been denied whitelisting, deleted or reinstated as a VAT payer. It is also a reliable way to check if the business partner’s bank account is correct. Additionally, the whitelist of VAT payers is a credible source of information about taxpayers, individuals and corporations. 

It includes[1]:
  • business name or full name of a business owner;
  • tax identification number, if available;
  • status of an entity:
  • which has not been whitelisted or which has been deleted;
  • which is whitelisted as a “VAT-registered taxpayer” or “exempt VAT payer”, including entity which has been reinstated;
  • statistical number REGON, if available;
  • National Court Register number, if available;
  • registered office address – applicable to non-individuals;
  • full names of people who are members of a body authorised to represent the entity and their tax identification numbers;
  • full names of commercial attorneys (prokurent), and their tax identification numbers;
  • full name or business name of shareholder and his/her/its tax identification number;
  • date of whitelisting, refusal of whitelisting or removal and reinstatement;
  • legal basis for refusal of whitelisting, removal from and reinstatement on the list;
  • checking account number at a bank or personal account in a credit union to which the company belongs, opened for the purpose of the business activity – specified in the registration application or updated registration form and confirmed using STIR.

The criteria and requirements for whitelisting

The whitelist of VAT payers is created by the Head of the National Revenue Administration who downloads the data from public records. Therefore, there are no additional steps to be taken to become whitelisted. If you notice that your company’s details on the whitelist are wrong, you can request the Head of NRA to remove or rectify them. Please remember that sole proprietors may operate outside the VAT system, e.g. due to small turnover, and therefore may not be whitelisted.

How to whitelist your company

Once you open a corporate bank account, you will need to specify the account number in the registration application or the updated registration form submitted to the revenue office. The bank should also disclose your account number to the ICT system of the clearing house (STIR). This is how corporate bank account numbers end up in the NRA’s database. And from there, they are automatically uploaded to the whitelist of taxpayers. 
If you change your corporate bank account number in the course of your business, you have to report it to the revenue office. Businesses entered in the National Court Register and civil-law partnerships use NIP-8 forms (registration application in respect of supplementary details of the National Court Register) and NIP-2 forms (updated registration of civil-law partnership’s details). Sole proprietors report changes via the Central Registry and Information on Economic Activity (Polish abbreviation: CEIDG). Every change of the competent revenue office also requires an updated registration form on which corporate bank accounts need to be disclosed.
Businesses entered in CEIDG may add their bank account number online (biznes.gov.pl). The electronic application requires the account number and account type, full name of the account holder, the bank’s registered office and its full name. 

How long you will have to wait to be whitelisted

Data are uploaded to the list automatically, and the whitelist is updated once a day. 

How to check an account against the whitelist of VAT payers

One of the most important details on the whitelist of VAT payers is the bank account number assigned to the business. The list of VAT payers may be searched according to at least one criterion:
  • tax identification number NIP
  • statistical number REGON
  • bank account number
  • enterprise name (business name or full name of a business owner). 

On the day you want to pay an invoice, you should check if the account number specified on the invoice matches the one on the whitelist. You should clarify any discrepancies with the payee before the payment. It is also worth checking if your own whitelisted bank account is correct. If you receive payments exceeding 15 thousand zloty and your account number is wrong, you expose your business partners to trouble. 

Whether you can transfer money to non-whitelisted accounts

Money transfers to non-whitelisted accounts are not safe. The following sanctions may kick in if the account number on an invoice for more than 15 thousand zloty is not whitelisted:
  • you and your business partner may face joint and several liability for tax arrears if your business partner does not pay VAT on the transaction;
  • the transferred amount is non-tax-deductible.
Still, you have 7 days to escape the sanctions if you happen to pay to a non-whitelisted account. To this end, you need to notify the head of your revenue office. The sanctions do not apply to payments in the split payment procedure.

Summary

The VAT whitelist is a fundamental tool in the due care procedure. If you follow the procedure and you are not aware that a purchase of goods has been designed as a tax fraud, you will retain the right to deduct input tax.

As a basic and reliable tool, the VAT whitelist helps businesses check, above all, if the payee is still a VAT-registered taxpayer. Additionally, it lets you check the correctness of bank account numbers to which you transfer money. To boost your transaction security, it is wort checking your business partners’ numbers every time on the transfer date.

Source:
[1] Biała lista podatników VAT – narzędzie do sprawdzania kontrahentów, biznes.gov.pl

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Przemysław Trzaska

Tax adviser (Poland)

Senior Associate

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