Poland's VAT white list: how to check bank accounts, when joint liability applies and how to use the available protection.
The white list of VAT taxpayers (biała lista podatników VAT) is an electronic register maintained by the Head of the National Revenue Administration (KAS) listing registered, unregistered and de-registered VAT entities. Its main purpose is to let businesses verify a counterparty's bank account before making transfers above PLN 15,000.
The register includes: the counterparty's VAT registration status (active, exempt, de-registered), bank account numbers filed with the tax office, registration and de-registration dates, and NIP/REGON numbers. It can be searched free of charge at podatki.gov.pl.
Paying more than PLN 15,000 to an account not on the white list risks: joint and several liability for the supplier's VAT arrears up to the invoice VAT amount, and loss of the right to deduct the expense for CIT/PIT purposes. Protection is unavailable if the account number is absent from the register on the payment date.
If you pay to an account outside the white list (e.g. an assignment account), file a ZAW-NR notification with the head of the relevant tax office within 7 days of the transfer. A timely notification removes joint liability and restores the right to a tax deduction. Since 2022 the notification goes to the buyer's tax office, not the seller's.
Verify the counterparty's bank account before every payment above PLN 15,000. Archive verification results with a date and time (printout or screenshot). For regular suppliers, run periodic checks (e.g. monthly). Use the Ministry of Finance API or accounting software with built-in verification.
The white list of VAT taxpayers protects your business from liability for others' tax failures. Danexis will implement counterparty verification procedures and shield your business from costly sanctions.