Compliance Alert - VAT law changes to advance payment invoicing

Poland has announced changes to its VAT law that affect advance payment invoicing. The amendments for both electronic and advance payment invoicing were officially published on 11 August 2023, but obligations for advanced payments came into force on 1 September 2023.

Suppliers must now document the receipt of advance payments with a tax-valid invoice. Once the supply is completed, the supplier must raise another invoice documenting the supply and making clear any deductions on the invoice for revenue already recognized in association with the payments. This rule applies even if the advance payment received is for the total amount of the supply.

Taxpayers can raise advance payment and standard tax invoices 60 days before the taxable event and no later than the 15th day of the month following the event.

However, if a taxpayer receives all or part of the payment for the supply of goods/provision of service in the same month in which they are performed, it is possible not to issue an advance payment invoice. In such cases, the taxpayer is allowed to raise only the invoice documenting the supply, which must provide both the date of supply and the date of advance payment receipt (if known and different than the date of invoice issuance).

These changes aim to minimize the number of VAT documents submitted by taxpayers each month if the taxable event, advance payment, and supply occur in the same period.