The obligation to mark deliveries and services (GTU) introduced on 1 October along with the new JPK_VAT raises many doubts among taxpayers. They apply to both goods and services that should be marked, as well as invoices related to them.

With the new JPK_VAT file, sellers will be required to mark certain goods and services with special numerical markings. Markings from "01" to "10" have been provided for selected goods, and markings from "11" to "13" for selected services.

It should be emphasized that the indicated obligation will be imposed only on sellers. Buyers of goods and services will not be required to indicate the following designations in the JPK_VAT files sent.

The new JPK_VAT file, containing the declaration and registration part, will be mandatory for all taxpayers registered as active VAT payers for the periods from October 1, 2020.

The designations introduced in the new JPK VAT with the declaration, e.g. MPP, MK, FP, TP, GTU, apply to all documents shown in JPK_V7M/JPK_V7K during its validity. They therefore apply to:

  • purchase invoices issued before the period of validity of the new structure, when the taxpayer will exercise the right to deduct during its period of validity,
  • correction invoices issued to invoices received before the introduction of JPK_V7M/JPK_V7K.

Importantly, GTU symbols should be used to mark the correcting invoice only in the case of a correction concerning goods/services covered by GTU symbols. This means that even if the original invoice contained goods/services to which GTU markings are applied, but the correction does not apply to them, the correcting invoice should not be marked in this way.

GTU designations also apply to:

  • advance invoices,
  • invoices marked "FP" issued to receipts for taxpayers,
  • second-hand goods for which the use of these codes is required,
  • re-invoicing services (if a taxpayer, acting on his own behalf but on behalf of a third party, participates in the provision of services, it is assumed that the taxpayer himself received and provided these services),
  • exports or intra-Community deliveries (transactions with 0% VAT), e.g. fuels, export of services, e.g. intangible,
  • Single Purpose Voucher (SPV) invoices that relate to goods or services covered by GTU codes.

If there are several items on the invoice, each of which qualifies for a different GTU, or one item qualifies for several GTUs, you can use multiple GTU markings for one invoice without dividing it into several entries.

GTU designations do not apply to:

  • aggregate information on sales not documented with invoices (also in a situation where only one such transfer occurred in a given period),
  • purchases which result in entries on the sales side at the taxpayer - buyer (e.g. WNT or import of services),
  • adjustment of the tax base and output tax, made in accordance with art. 89a sec. 1 and 4 uptu,
  • aggregate information on sales recorded at the cash register.

Correction of erroneous GTU markings If, despite a properly issued invoice, errors have been made in the records, the correction of incorrect GTU markings can be made in two alternative ways. By:

  • complete replacement of the incorrect entry with the correct one - this method is preferred when the correction occurs before submitting the original file that contains the error,
  • leaving the incorrect entry and adding two more, i.e.: the first one with identical data (including incorrect GTU markings) and the reverse sign next to the amount data in the "K" fields, and the second one containing correct entries, including GTU markings.

In this way, you can correct an error in posting an invoice, regardless of how many GTU markings were made in error. In the case of a change that does not affect the declaration part, it is enough to correct the registration part itself.

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