Accounting duties are growing

JPK, MDR, PPE, OSS, TPR-C and TPR-P. These are not names of medicines, biochemical compounds, or synthetic vitamins. These are shorthands known to each accountant serving Polish taxpayers, specifying the requirements of the regulations before them. From 31 July AML will also be listed among them.

With each amendment to the rules, with each change in taxes, bills or allowances, the amount of obligations imposed on accountants by legislators increases. Although attempts are made from time to time to reduce this burden or to remove burdensome and unnecessary changes, they are often insufficient or even more confusing. This is the case, among others, for continuous changes in the structure of VAT JPK or a package of changes which are referred to as ‘SLIM VAT’.

Old responsibilities

VAT JPK is the IT structure of the ‘single control file’ introduced into Polish tax law in 2016[1]. This is the Polish equivalent of SAF-T. Its introduction aimed at removing barriers to the transmission of electronic data, and was later also integrated with VAT returns, creating a currently known structure.

MDR is short for the Mandatory Disclosure Rules or tax scheme reports. The obligation to prepare and report such reports was introduced under the Amending Act from 23 October 2018[2] and Act dated 29 August 1997 - Tax Ordinance (i.e. Journal of Laws of 2020, item 1325 as amended, Next: Tax Ordinance).

The EPP is the form needed for the settlement of flat-rate income tax on revenues recorded by estimating the company's tax on the basis of the entire income. The OSS (One Stop Shop) procedure is a new accounting procedure for inter alia intra-Community distance selling.

On the other hand, TPR-C and TPR-P are forms for legal and natural persons, respectively, to provide information on transactions between related parties.

And new

From 31 July new responsibilities related to the AML Act,[3] They'll be sleeping with an accountant. That's when it comes into force. Act dated 30 March 2021 amending the anti-money laundering and terrorist financing Act and some other laws (Journal of Laws, item 815). It extends the definition of the obliged institution, i.e.

an entity that has to fulfil its obligations to identify and verify entities or transactions that may give rise to suspected money laundering or terrorist financing, to entities operating in the field of bookkeeping services, regardless of the form of the activity.

Introduced into the AML Act Article 2(1)(15a) provides that the institution is ‘entrepreneurs within the meaning of Act dated 6 March 2018 - Business law (Journal of Laws of 2021, item 162), whose main economic activity is the provision of services consisting in making declarations, keeping tax books, providing advice, opinions or explanations in the field of tax or customs legislation, which are not other obliged institutions.’

This change is intended to allow money laundering to be detected at every stage of the economic trade. The earlier the detection, the more effective the supervisory instruments and the blocking of funds from illegal sources, and the more effective the prosecution authorities are in mind. This is not surprising, therefore, because who, if not the accounting entities, has the most information and can provide valuable evidence of such harmful behaviour.

It is also important to identify real beneficiaries among the new obligations[4] supported companies based on Article 34(1). point 2, Article 36(2) is Article 37 AML laws. To this end, they should implement appropriate procedures, which is undoubtedly a difficult task for those not familiar with the rules. However, non-execution of obligations imposed by the Act may result in financial penalties[5].

The Act provides for a number of obligations such as:

• creating an internal procedure,
• making risk assessments for customers and their transactions
• designation of persons responsible for carrying out AML duties,
• the application of certain financial security measures,
• regular training,
• the introduction of internal control rules,
• reporting to the General Financial Information Inspector,
• the maintenance and storage of documentation confirming the performance of duties.

Responsibilities increase, wages fall

As you can see, the number of duties imposed on accountants is rather increasing. It would therefore also be natural to increase earnings. However, according to Antal's analysis and wage reports 2021[6]  average wage in the finance and accounting industry fell from 11,938 PLN to 10,329 PLN. It was also the biggest drop among specialists in the amount 13%. This means reducing the average salary to pre- 2017 where according to Antal's salary report 2019 was 10,861 PLN.

Source: Antal Payment Report 2021

On the other hand, data from the National Remuneration Survey[7] indicate that the remuneration of the accounting officer is presented in accordance with the table below.

Table showing the interval between quarterly gross earnings of the accounting officer

first quartile

3,920 PLN

Median

4,820 PLN

third quartile

5,990 PLN

Source: https://wynagrodzenia.pl/moja-placa/ile-zarabia-ksiegowy

This means that only 25% of the respondents made more than 4,312 net.

Although legislators, often without consultation, are eager to impose new responsibilities on accounting offices and accountants, this rarely translates into an increase in their real earnings. Indeed, customers often do not want to bear additional costs, even if this is to allow them to reduce the risk of adverse tax controls and/or fines.

Damian Kuszewski

The author is a graduate of the Warsaw School of Economics in Finance and Accounting, and a graduate of the Faculty of Law at SWPS. From 2018 Associated with Russel Bedford Poland. His professional interests are tax law and, in particular, income taxes.