Obligatory split payment was introduced in Poland on the 1st of November 2019. The mechanism concerns invoices with total gross amount exceeding PLN 15000 for goods and services listed in the new Annex 15 to the VAT Act. In such cases, the seller (service provider) is required to mark the invoices with the note “split payment mechanism”. In practice it means that if the invoice includes goods/services outside of the Annex 15 but also at least one item form this annex (even in a very small amount), but the entire amount of the invoice (gross) exceeds PLN 15000, the seller is required to include the wording “mechanism split payment “and the buyer must pay it using split payment.
There is however an option to split such invoice into two invoices so that only one of the invoices contains the goods from the Annex 15. The other goods or services can be included on the second invoice.
The Ministry of Finance confirmed such division is acceptable. As the ministry explained the PLN 15000 limit applies to the gross amount indicated on the invoice. Therefore, if the taxpayer buys the goods/services listed in Annex 15 to the VAT Act on one invoice with amount lower than PLN 15000, and the goods/services not included in the annex on the second invoice, the split payment mechanism does not have to be used.