Online cash registers

On 15 March 2019 the Act amending the Goods and Services Tax Act and the Act has been passed - Law of measurement 1 (Further: u.z.p.t.u.), which introduced the obligation to use online cash registers instead of traditional fiscal devices. The changes are linked to the constant fight by the legislature to seal the tax system.

New solutions are intended to enable tax authorities to gain knowledge of current retail sales. Currently, the control of fiscal receipts, due to their number and paper form, is virtually impossible.

The introduction of online cash registers makes access to these data not only simpler, but also allows authorities to keep track of information about taxable persons' transactions – including, for example, the number of receipts cancelled or periods where sales are not recorded.

Such data may be used to better appoint a taxpayer for inspection.

1. Sectors subject to the new obligation

The rules entered into force 1 May 2019 Tax payers from this term can already use online cash registers voluntarily. However, companies are not required to exchange cash registers immediately, except for the industries defined directly in the Act with 11 March 2004 on tax on goods and services 2 (Next: the VAT Act). Indicate here Article 145b the VAT Act According to its content, taxpayers must keep records of sales using online cash registers within the period from 1 January 2020 – in relation to:

• 1) the provision of repair services for motor vehicles and mopeds, including tyre repairs, their establishment, retreading and regeneration, and the replacement of tyres or wheels for motor vehicles and mopeds,
• 2) sale of motor gasoline, diesel, gas for internal combustion engines.

From 1 July 2020 This obligation will also apply to:

• 1) the provision of catering services exclusively provided by fixed catering establishments, including seasonally, and short-term accommodation services,
• 2) the sale of coal, briquette and similar solid fuels produced from coal, lignite, coke and semi-coking for heating purposes.

From 1 January 2020 Online cash registers must be used to provide services:

• 1) hairdressing,
• 2) cosmetic and cosmetic,
• 3) construction,
• 4) for medical care provided by doctors and dentists,
• 5) Legal,
• 6) business-related facilities to improve physical fitness – only for access to these places (e.g. a fitness club).

Of which: Under Article 145b the VAT Act According to the MF, the catalogue may be presumed to be the biggest abuses in the sectors listed therein. It therefore seems reasonable that tax authorities will look more closely at these retail sectors.

According to the individual interpretation presented below by the Director of KIS, the exchange of cash registers is also covered by grocery stores which offer only food services provided by fixed catering establishments (e.g. sale of hot dogs or casseroles).

Individual interpretation of the Director of KIS from 31 October 2019 3

In the present case, therefore, the sales points (shops) which the applicant operates (at the place where the commercial service is provided) where casseroles, hot dogs, tortillas and panini are sold should be considered as a catering point.

Therefore, in view of the above legal provisions resulting from the provisions laid down, it should be concluded that, as the case is described in the case, the applicant also operates a point of sale of catering services, according to the record Article 145b(1)(2) the VAT Act will be required to keep records of sales to natural persons not engaged in business activities from 1 July 2020 using online cash, i.e.

a cash register allowing the connection and transmission of data between the register office and the Central Repository of Kas, taking into account the provision Article 145b(2) the VAT Act

Thus, where the taxable person combines the sales covered by the online cash registers with those which are not subject to that requirement, he will be subject to the obligation to exchange the cash registers described above.

However, if sales are carried out, for example, in a taxable person’s branch that does not provide services and does not sell goods for which the use of online cash registers will be mandatory, there will be no need for online cash registers at these points.

This is confirmed by the individual interpretation presented below by the Director of KIS.

Individual interpretation of the Director of KIS from 29 November 2019 4

As already indicated, this obligation applies only to the register offices under which the sales of the goods or services listed are recorded under Article 145b(1) the VAT Act At this point it should be pointed out that the sale of parts and accessories for means of transport carried out in the subsidiary of the Applicant is not mentioned in the provision Article 145b(1) the VAT Act as a sale which is subject to an exchange of online money within the time limit specified in that provision.

In the light of the legal regulations resulting from the provisions laid down, it should be concluded that, for the economic activity carried out by the Applicant in an ‘additional location’, the sales records may continue to be made using a register office with an electronic record of the copy.

As the applicant himself indicated, only the sale of parts and accessories to means of transport is carried out in the branch.

Therefore, since the sales of goods carried out by the Applicant at the ‘additional place’ of business have not been mentioned under Article 145b(1) the VAT Act as an obligation to keep records using online cash registers, The applicant may still use a cash register with an electronic record of the copy at this point. (...)

(….)

It is clear from the description of the case that the applicant does not sell the goods and services listed in the provision Article 145b(1) the VAT Act As indicated by the Applicant, his business is to sell used motorcycles or their parts.

After buying a motorcycle, the applicant shall sell it or repair it if it is damaged and then sell it. The applicant pointed out that it does not actually provide repair services for motor vehicles owned by the customer; he stressed that it only fixes its own vehicle purchased for the purpose of reselling the motorcycle.

The applicant shall supply goods rather than services. At this point, it should be pointed out that the sale of used motorcycles or parts thereof is not mentioned in the provision Article 145b(1) the VAT Act as a sale which is subject to an exchange of online money within the time limit specified in that provision.

The above interpretation rightly concludes that if an entity performs repair services which are subsequently sold, there is no obligation to use online cash registers. Thus, the majority of businesses purchasing used cars and repairing them on their own are not obliged to use online cash registers.

2. Time limits for using fiscal cash registers without online functions

Tax payers may continue to use electronic cash registers or those with a paper record of non-listed copies under Article 145b(1) the VAT Act However, confirmation of the performance of the functions, criteria and technical conditions for register offices:

• 1) are issued to cash registers with an electronic record of copies, to 31 December 2022,
• 2) were issued to cash registers with a paper record of the copies to 31 August 2019

Therefore, the old types of cash registers can continue to be purchased (until the deadline indicated above) and used until the validity of the confirmation of the performance of the functions, criteria and technical conditions for the registers has expired.

Mandatory online cash registers must introduce tax payers of the professions and industries indicated under Article 145b the VAT Act For non-listed industries under Article 145b the VAT Act, non-on-line cash registers will be eliminated from trading over time.

This will be mainly due to the lack of the possibility of obtaining confirmation of compliance with technical conditions. Therefore, the process of introducing full online cash registers will be strongly stretched over time.

For some taxpayers, buying a cash register without an online function may be more beneficial, as there is no need for changes to ensure that the cash register has permanent access to the telecommunications network.

Thus, fiscal cash registers other than online will only disappear at the end of the validity of the confirmation obtained on the performance of the functions, criteria and technical conditions for recording banks.

3. Central Kas Repository – new data collection and analysis system

Due to the introduction of online cash registers, the Central Repository of Kas (CRK) was created. This is an information system for:

1) receiving and collecting data from the register offices, including:

(a) sales data,

(b) data on events recorded in the memory of the register offices relevant to the work of the register offices which have occurred in the use of those registers, including the fiscalisation of the register, changes in tax rates, changes in the address of the point of sale and the dates of technical reviews;

2) analysis and control of data from recording offices;

1. to send instructions to the register offices concerning the work of the register offices.
2. 1. Liability for merger with the CRK on the taxpayer’s side

Online cash registers are to connect to the CRK via a telecommunications network. The VAT Act stipulates that this connection must provide:

1. the direct, continuous, automated or at the request of the Head of the KAS data from the register offices to the CRK, in the electronic form of an appropriate logical structure;
2. the transmission and receipt of orders from the CRK to the register offices concerning the operation of the cash registers:

(a) relating to the fiscalisation of the register office,

(b) including:

• – the method and scope of the transmission of data from that register,
• – how the register office works,

(c) ensuring that the work of the register office is correct.

Subsequently, the Head of the KAS shall make the data from the register offices collected in the CRK available to the Minister responsible for public finances, to the directors of the chambers of fiscal administration, to the heads of tax offices and to the heads of customs and tax offices, to the extent necessary to carry out the statutory duties. It should be stressed that no identification of the buyer will be made available to the CRK from the online cash registers, except the NIP number, which will be provided for subsequent invoice issuance.

In the Finance Minister’s regulation on cash registers with 30 April 2019 5 (Further: (r) it has been indicated that the taxpayer is obliged to provide a connection allowing the automatic or on-demand transmission of data between the online cash register and the CRK, in accordance with the data transmission schedule. Automatic transfer of online cash register data to the CRK is subject to fiscal and non-fiscal documents and other data related to the use of the cash register, recorded in the protected memory since the previous automatic transfer of data.

In the event of a change in the place of use of online cash register, the taxpayer should ensure that fiscal and protected memory and the book of current cash registers can be recorded in the register after the change in the place of use of the cash register has been made.

When a taxable person is unable to ensure the permanent merger of his cash with the CRK, and this is due to reasons beyond his control, if the reason is temporary, he is obliged to keep records of the sale and to provide that connection immediately after the cessation of the reasons originally preventing the merger from being established.

An example of such a situation is, for example, a temporary lack of range. At the time of the occurrence of permanent reasons, the taxable person shall keep records of the sale and, with the agreement of the head of the tax office, shall ensure this combination at intervals fixed with the head of the tax office.

Such a solution concerns a situation where there is no range of ICT networks at the place of continuous sale, such as mountain tourism. In Annex 2 a template for the request for consent to transfer data from the cash register to the CRK at fixed intervals is indicated.

3.2. Scope of fiscalisation

According to Article 22 in time 7 the days from the date on which the fiscalisation was carried out, the taxable person shall submit to the competent head of the tax office, in order to receive the registration number, a declaration of the cash register data (according to a particular template).

This obligation does not apply to online cash registers for which the fiscalisation will take place through the system.

According to the r.k.r., the taxpayer, with the help of a service provider, is taxing before starting to keep records using online cash registers, providing a connection to transfer data between online cash registers and CRKs.

Fiscalisation shall include:

• 1) sending a public money key,
• 2) a request for fiscalisation,
• 3) receiving an identification number,
• 4) irreversible record in fiscal memory of the fact, date and time of fiscalisation,
• 5) the initialisation of the work of fiscal and protected memory and the unambiguously irreversible link between these memories,
• 6) zeroing all cash counters,
• 7) a unique and irreversible record in the fiscal memory of the taxpayer's tax identification number (NIP) and a record in the fiscal memory of the registration number,
• 8) record in the memory of the protected registration number,
• 9) the fiscal memory of the category of cash register, if the cash register's work programme allows the cash register to combine different categories of cash register,
• 10) the presentation of a fiscal report on fiscalisation,
• 11) reporting of fiscalisation by sending a fiscal report to the CRK,
• 12) download and record in the protected data transmission schedule memory.

In the case of online cash registers, there is no obligation to notify the fiscalisation of the cash register as the process is carried out by the service provider itself and the data is then sent to the CRK.

3.3. Applicable tax payer’s documentation

Tax payers keeping records using online cash registers shall issue:

• 1) fiscal receipts and receipts cancelled in paper and electronic form,
• 2) invoices and invoices cancelled in paper and electronic form,
• 3) Daily reports in electronic form,
• 4) fiscal reports of paper and electronic fiscalisation,
• 5) Periodic fiscal reports, including monthly, in paper form,
• 6) fiscal accounting reports in paper form,
• 7) total interim fiscal reports, including monthly, in paper form,
• 8) total paper-based fiscal clearance reports,
• 9) fiscal reports of events in paper form,
• 10) non-fiscal documents in paper or electronic form
• – containing the data specified in the technical requirements (criteria and technical conditions) provisions for cash registers.

If the taxable person maintains a register using a special online cash register (e.g. cash register for the carriage of persons, for the sale of medicines with a prescription clearing function, for the provision of passenger transport services or installed in devices for automatic sale), the fiscal receipt shall contain data specific to the specific characteristics of the sales or records to be kept, identified and placed in the appropriate order, in accordance with the provisions of the year.

3.4. Clearance of return packages

The taxpayer settles using an online register of returnable packages only by issuing a non-fiscal document. Such a document shall contain a data block specifying the settlement of returnable packages and information on the payment for sales included as a fiscal receipt (at least the indication ‘FOR REPAYMENT’ or ‘FOR RETURN’ or ‘Price’ together with the amount of the claim after taking account of the settlement of returnable packages).

4. Exchange of fiscal storage

The use of online cash may involve the obligation to exchange fiscal memory. Before exchanging protected memory, a taxpayer using online cash registers must record the data from the protected memory to an external data medium unless the memory has been damaged.

If the need for the exchange of online cash registers is due to its filling or damage, the taxpayer shall ensure that the activities specified for the termination of online cash register use (except for the submission of an application for the deregistration of the cash register) and shall be responsible for the replacement of the protected memory.

After the exchange of protected memory, re-fiscalise online cash registers. Importantly, the exchange of protected memory is performed only by the operator conducting the main service.

5. Renting online money by a taxpayer

In the course of business, the taxable person may keep records of his own sale using an online cash register accepted for use on the basis of a written lease, lease, lease or other similar contract concluded with the person giving the cashier the use if:

• 1) has been acquired by the entity giving the cash register for use during the period of validity of the confirmation by the President of the Main Measurement Office that they fulfil the required functions,
• 2) has a new unwritten fiscal memory and a protected memory. The taxpayer does not have to buy his own online money, for example, he can rent it.

For the duration of the contract with the party hiring the cash register, the transferor must ensure the exchange of fiscal and protected memory in cases of filling or damage.

When entering into a lease, lease, lease of an online cash register or other similar contract with a taxable person, the transferor shall be obliged to transfer:

1. the name and address of the place of business or the address of the head office of the service provider or the service provider; and
2. a copy of the document confirming the acquisition of the cash register or the declaration of acquisition of the cash register, including in particular the date of its acquisition and the invoice number, and, where the acquisition was not documented by an invoice, the date of its acquisition and the data enabling the identification of the document supporting that fact.
3. Completion of economic activities

If the use of online cash registers is terminated due to the cessation of the business activity or the working of these funds on a fiscal basis, the taxable person shall:

1) issue a daily fiscal report;

1. immediately after the automatic transfer of the cash register to read-only mode or after the provision, by means of a serviceman, of the cash register to read-only mode, it shall, also with the help of a serviceman, read the fiscal memory content by issuing a fiscal billing report or a total fiscal billing report, and draw up a protocol from that exercise according to the formula used Annex 4 to r.k.r.;
2. submit a report from reading the contents of the cash register's fiscal storage together with the attached billing fiscal report or the total billing fiscal report, within the time limit 5 the days from the date on which they were drawn up to the taxable person of the head of the tax office;
3. draw up and submit, together with the documents in question Under point 3, to the taxable person of the head of the tax office, the application for the removal of funds from the register of accounts, in accordance with the formula Annex 5 to r.k.r.

When the online cash register is completed, the taxpayer shall ensure that the data from the protected memory is read and recorded on an external data medium. In the event that the online work is completed in fiscal terms, the taxpayer may not keep records using it.

7. Mandatory statement by the registrant

According to Article 6(3)(4) There is a new obligation for the taxpayer.

It must inform the person keeping the register before, and regardless of the manner and form of entrusting that person to keep the records, of the principles of the records, including the basic principles of keeping the records and issuing the fiscal receipt and the consequences of not complying with them.

The taxpayer must also obtain a statement from that person that he is familiar with the rules of registration. This declaration shall be made in two copies, after one for the taxable person and the person keeping the records. The content of this declaration has been indicated In Annex 1 to r.k.r.

According to him, the person keeping records with the taxpayer using the register office must make the following declaration. The statement must be kept in the company, not transferred to the tax office.

Model declaration

I declare that the taxpayer has introduced me to the rules of keeping sales records using the register office and issuing the fiscal receipt and the consequences of non-compliance with these rules, which are covered by the registration rules. I declare that I know the duties indicated in the record-keeping information.

I know that for selling with the exception of the register office or failing to issue a fiscal receipt (invoice), including a release from the register office of a document other than a fiscal receipt (invoice), I can be fined for fiscal criminal offence either fiscal misdemeanour.

8. Amendments to the Fiscal cash registers Regulation

On 25 March 2020 was presented a project amending the year.

That Regulation provides for the adaptation of the provisions of the year to the changes resulting from the Act on 31 March 2020 amending the Act on Special Solutions for Prevention, Prevention and Control COVID-19, other infectious diseases and their emergency situations and certain other laws 6 (hereinafter: UCOVIDzm).

According to the draft amending year, the definition of a document in electronic form is changed.

In accordance with its intended new wording, such a document shall mean the set of structured and structured data from fiscal and non-fiscal documents created by the online money, recorded in fiscal memory or protected memory, in the format specified in the communication protocol of data transmission for fiscal documents.

Previously, the electronic document was only the one sent to the CRK. According to the planned amendment, the transmission to the CRK has been deleted and its place indicates that it is to be in the format specified in the communication protocol for the transmission of data for fiscal documents. To Article 6(10) a new registration requirement will also be introduced.

According to its content, tax collectors will have to check the correctness of the document issued before approving the fiscal receipt or invoice, in order to eliminate obvious errors in the records. The content of the statement by the person keeping records with the taxable person using the register office shall also be changed. After the planned amendment, it will have the content set out in the formula below.

Model declaration

I declare that the taxpayer has introduced me to the rules for keeping records of sales using the register office, issuing and issuing the fiscal receipt and the consequences of non-compliance with those rules, which are covered by the registration rules. I declare that I know the duties indicated in the record-keeping information.

I know that for selling with the exception of a register office or failing to issue a fiscal receipt (invoice), including a cash register issue instead of a fiscal receipt (invoice) of another document, I can be fined for fiscal criminal offence either fiscal misdemeanour.

This added the requirement that the person also declares that he was familiar with the principles of issuing the fiscal receipt. The other amendments shall be editorial or adaptation to the changes concerning e-paragons described Under point 10.

9. Tax credit for buying online cash registers

It should be noted that, when exchanging cash registers, it is possible to benefit from the relief provided for in the provisions. According to Article 111(4) the VAT Act taxable persons who:

• 1) Whereas it is mandatory to keep records of sales and which, within the applicable time limits, have begun to keep records of sales using online registers;
• 2) there was no obligation to keep records and who voluntarily started keeping sales records using online cash registers and had previously not used other types of cash registers to keep sales records;
• 3) there has been an obligation to exchange registers with electronic or paper recording of copies to online cash registers due to activities carried out in specific industries

• they have the right to deduct from the tax the amount due for the purchase of each of the register offices, in the amount of 90% its purchase price (without tax). However, that amount may not exceed 700 PLN. Where this amount is higher than the amount of tax due in the accounting period, taxable persons shall have the right to reimburse the difference to the bank account of the taxpayer in a bank established in the territory of the country or in the account of the taxpayer in the SKOK of which he is a member, or to deduct from the tax due that difference for subsequent periods of account, provided that the purchase of the register offices has taken place no later than the time limit 6 months after the start of that record. The relief is only available for the purchase of online cash registers.

From 30 April 2019 it is not possible to benefit from the relief in the case of cash registers with electronic or paper records of copies. Unfortunately, taxpayers who voluntarily exchange money that has electronic or paper copies and are not taxable in the sectors covered by mandatory online cash registers cannot benefit from the relief.

On 29 April 2019 a regulation was issued by the Minister of Finance on the deduction or reimbursement of amounts spent for the purchase of the register offices and the reimbursement of those amounts by the taxable person 7 (Further: r.o.k.r.). That Regulation lays down the conditions, manner and manner of deduction from tax due or reimbursement of amounts spent for the purchase of register offices. The deduction of the amount spent on the purchase of an online register office or its reimbursement shall be made if the following conditions are met:

• 1) start keeping records of sales by the taxable person using the register office purchased during the period of validity of the confirmation that the register meets the technical requirements,
• 2) the taxable person has an invoice confirming the purchase of the register office and proof of payment of the total amount due for its purchase. These provisions are controversial.

Individual interpretation of the Director of KIS from 13 November 2019 8

„Relief" for the purchase of cash will be due only on those funds that are exchanged in connection with the obligation to use online cash registers by the groups of taxpayers concerned. In view of the above, it must be concluded that the taxable person obliged to exchange cash registers which will purchase online cash registers to new outlets (i.e. the purchase is not related to the exchange of cash at a given point) will not be able to benefit from the so-called relief for the purchase of register offices intended for these new points. Given the above in the light of the circumstances set out in the request, and in particular the fact that the applicant purchased the online cash voluntarily in connection with the opening of the new point of sale, it should be concluded that since that cashier was not acquired in connection with the exchange of the online cash register, The applicant may not benefit from the right to ‘ulg’ for the purchase of online cash.

The same position was indicated in the interpretation of the individual Director of the National Tax Administration from 23 August 2019 9 . The Authority therefore considered that, in the case of the purchase of online cash registers which the taxable person must obligatoryly purchase to a new point, he is not entitled to any relief.

Such an approach significantly restricts the use of the benefit only to funds exchanged by taxpayers. The deduction of the allowance shall be made in the VAT tax return for the period during which the sales records were kept using the register office or for periods following that accounting period.

Some doubts were also raised by the time when taxpayers can benefit from the relief – whether they have the right to do so after buying, or when the statutory obligation to use online cash registers comes into force. On 11 July 2019 Minister of Finance issued tax explanations on this matter[10].

According to the document, a taxable person obliged to exchange cash registers, who will start installing online cash registers before the deadline indicated in the Act (and will start keeping sales records on them), has the right to reimburse the allowance for the purchase of online cash registers before the limit date for the use of online cash registers.

The following example of deduction is given in the explanations.

Example

A car repair service taxpayer uses a cash register with electronic copy recording.

This taxpayer, according to the VAT Act, must keep records using online cash registers from 1 January 2020 The taxpayer purchases cash In June 2019 and starts keeping records with this register In June 2019 In this case, the taxpayer will be able to demonstrate ,,ulga’ for online money according to section 3 section 1 r.o.k.r.

in a declaration made for the period during which he actually started keeping sales records on the cash register concerned, i.e. in the declaration for June 2019

10. E-paragon

In UCOVIDZEM was redeveloped Article 111 the VAT Act on the register offices. Amendment concerned section 3a point 1 Article 111 the VAT Act In accordance with the new wording of this provision, taxable persons keeping sales records using register offices shall:

1) issue and issue to the purchaser a fiscal receipt or invoice for each sale:

(a) in paper form or

(b) with the consent of the buyer, in electronic form, by sending that document in a manner agreed with him.

In this way, the possibility for entrepreneurs to use e-paragons was introduced.

11. Virtual cash registers

According to Article 111b the VAT Act taxpayers have the possibility to use registers in the form of software, i.e. virtual cash registers. However, there are no implementing rules to be issued under Article 111b(3) the VAT Act, prevents the use of this solution. In implementing rules, the Minister competent for public finances may specify, by means of a regulation:

• 1) groups of taxable persons or types of activities for which virtual register offices can be used,
• 2) technical requirements for virtual recording booths and
• 3) the use of virtual registers, including the keeping of records of sales using them,
• 4) how to end the use of virtual registers in the event of the cessation of economic activity or the work of such registers; and
• 5) specific cases and ways of issuing documents in a form other than a printout using virtual register offices.

Thus, without implementing rules, taxpayers cannot benefit from a virtual cash register solution. Processed two draft regulations concerning both groups of taxpayers and the technical requirements to be met by these funds. According to the draft regulation, 10 March 2020 on groups of taxable persons or types of activities in respect of which it is possible to use register offices in the form of software may be used by taxable persons providing the following services:

• 1) the carriage of passengers by passenger car, including taxi, except for the occasional transport referred to under Article 18(4b)(2) Road Transport Act 11 ,
• 2) car rental with driver (PKWiU 49.32.12.0),
• 3) related to removals for households (PKWiU 49.42.11.0),
• 4) road passenger transport by vehicles propelled by human muscle or drawn by animals (PKWiU 49.39.35.0),
• 5) passenger, scheduled, interurban, public transport (PKWiU 49.39.11.0),
• 6) passenger, scheduled, urban and suburban road transport (PKWiU 49.31.21.0),
• 7) passenger, urban and suburban rail transport (PKWiU 49.31.10.0),
• 8) passenger transport, cable cars, cable cars and ski lifts (PKWiU 49.39.20.0),
• 9) maritime and coastal passenger transport by ferry (PKWiU 50.10.11.0),
• 10) maritime and coastal transport of passengers (PKWiU 50.10.12.0),
• 11) Inland passenger transport by ferry (PKWiU 50.30.11.0),
• 12) inland waterway passenger transport (PKWiU 50.30.12.0),
• 13) other inland passenger water transport (PKWiU 50.30.19.0),
• 14) regular domestic passenger air transport (PKWiU 51.10.11.0),
• 15) Non-scheduled domestic passenger air transport (excluding for observation purposes) (PKWiU 51.10.12.0).

Accordingly, the possibility of using virtual cash registers will not be available to all taxpayers, but only to selected groups. If this scope is not extended, for example, small traders or services not listed in the catalogue indicated in the Regulation will not be able to benefit from this possibility.

Such a restriction should be assessed critically as it was intended to facilitate business, especially for small entrepreneurs.

With regard to the Finance Minister's regulation on registration banks in the form of software regarding technical requirements, it should be pointed out that first the project was published In August 2019 Until January 2020 work continued on its final shape.

This project was then submitted for notification to the European Commission, which to 30 April 2020 has time to work on this legal act.

The final form of the regulations on groups that can use virtual cash registers and technical requirements that these devices must meet must be provided by taxpayers until the implementation rules are completed.

It should be indicated that, without the Regulation on technical requirements, such cash registers cannot be kept by virtual cash registers.

__________________________________________

Legal basis

1. Article 111(4), Article 145b the VAT Act,

1. Article 6(3)(4), Article 22, Annex 4, Annex 5 r.k.r.

The article comes from the book “Changes in Taxes and Accounting 2020 taking into account the anti-crisis shield" under the ed. prof. adjunct. dr. hab. Artur Hołda, published by C.H. Beck Publishing House: https://www.ksiegarnia.beck.pl/19149-zmianyw-podatkach-i-ksiegowosci-2020-z-uwzglednieniem-tarczy-antykryzysowej-artur-holda