From the interpretation of individual tax law, on the principles of registration and identification of taxpayers and payers in the absence of a virtual account reporting obligation issued 15 November 2019, we learn that virtual accounts are not billing accounts within the meaning of Article 49(1)(1) Act of 29 August 1997 Bank law (Journal of Laws of 2018, item 2187), Therefore, the applicant is not obliged to report them to the warden of the competent tax office. Therefore, virtual accounts will not be included in the list based on Article 96b Act of 11 March 2004 on tax on goods and services (Journal of Laws of 2018, item 2174) by the Head of the National Tax Administration.
The request for interpretation was made by a taxpayer who generates virtual accounts for its customers. These accounts are individual, so each customer receives a unique number assigned to him, which he uses to pay for the goods or services. The applicant wanted to make sure that he was not obliged to report virtual accounts to his customers.
According to the Director of National Tax Information, virtual accounts are not billing accounts and therefore do not need to be reported to the head of the competent tax office
The position that the taxpayer is not obliged to report virtual accounts was confirmed by the Director of National Tax Information.
It indicated that if each single client receives a unique account number assigned to it, which is used to transfer payment for a commodity or service, and the cash ultimately affects one the actual account of the Applicant to whom these virtual numbers are assigned, the virtual number shall be used only for automated settlement.
He also pointed out that the bank does not physically book virtual accounts or generate bank statements for them. The Director of KIS pointed out that in such a case the virtual account is not a billing account, and therefore the taxpayer is not obliged to report it to the tax office.
In conclusion, virtual accounts are not billing accounts within the meaning of banking law and companies are not required to report virtual accounts to the warden of the competent tax office. Nor will they be shown by the Head of National Tax Administration in the list of entities registered as VAT payers.
On the basis of an interpretation of the individual tax law of the Director of National Tax Information at 15 November 2019 The signal. 0111-KDIB3-2.4018.16.2019.1.MD