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Polish VAT white list and split payment from 2027: fewer PIT and CIT sanctions

03.11.2026 All posts

From 1 January 2027, a business will no longer automatically lose a deductible PIT or CIT cost solely because it paid a supplier into an account outside the Polish VAT white list or failed to use mandatory split payment. This is a material simplification, but it is not permission to discontinue payment controls.

The amendment removes additional income tax consequences. It does not change the basic rules for business-to-business payments or the liabilities arising under the VAT Act. The VAT white list, the split-payment transfer message and ZAW-NR will remain part of a safe payment process.

1. Which income tax sanctions will disappear?

Until the end of 2026, PIT and CIT rules impose additional consequences when a qualifying payment is made into an account outside the VAT taxpayer list or without mandatory split payment. The taxpayer may have to remove the expenditure from deductible costs or, when a cost reduction is not possible, increase taxable revenue.

From 2027, payment to an off-list account will not by itself deny a PIT or CIT cost, subject to the transitional provisions.
From 2027, failure to use mandatory split payment will not by itself deny a PIT or CIT cost, again subject to the transitional provisions.
The corresponding obligation to increase revenue when costs cannot be reduced will also disappear.

2. The invoice date determines which rules apply

The transitional rule is critical. Payments arising from an invoice issued before 1 January 2027 remain subject to the current PIT and CIT rules. A December 2026 invoice paid in January 2027 may therefore still trigger the old income tax consequences.

Timing	PIT/CIT treatment
Invoice issued by 31 Dec 2026	Existing sanctions may still apply even if payment is made in 2027
Invoice issued from 1 Jan 2027	No automatic cost denial solely because of an off-list account or missing MPP
VAT consequences	Assessed separately and remain relevant

Accounting systems and payment approval procedures should therefore capture both the transfer date and the invoice issue date. During the first months of 2027, one payment process may contain documents governed by both the old and the new rules.

3. The Polish VAT white list after 1 January 2027

The white list will continue to confirm a supplier's VAT status and bank account reported to the tax administration. For a transaction exceeding PLN 15,000, payment to an off-list account may create joint and several liability for the supplier's VAT arrears.

For invoices issued from 1 January 2027, such a payment will no longer automatically deny a PIT or CIT cost. This does not make account verification redundant. The check continues to reduce VAT risk and supports evidence of due diligence.

ZAW-NR will remain relevant as a way to mitigate joint VAT liability. Under the current official guidance, the notice is filed within seven days from ordering a transfer to an off-list account. Businesses should confirm the current deadline and filing method in the Polish e-Tax Office before acting.

4. Mandatory split payment remains in VAT

Mandatory MPP applies when the statutory conditions are met together: the invoice exceeds PLN 15,000 gross, at least one item is listed in Annex 15 to the VAT Act, and both parties are VAT taxpayers. The payment is made in Polish zloty using the dedicated bank transfer message.

From 2027, a buyer will not lose a PIT or CIT cost solely because it omitted MPP for an invoice issued from the start of 2027. A VAT surcharge equal to 30% of the VAT attributable to items covered by mandatory MPP may still arise. Fiscal penal liability may also remain relevant.

The seller must still mark a qualifying invoice with the wording required for the split-payment mechanism. Missing wording may result in an additional VAT liability unless the statutory conditions for avoiding the sanction are met.

5. Cash payments above the statutory limit may still deny a cost

The amendment does not repeal the rule for payments made without a payment account. If a transaction covered by Article 19 of the Entrepreneurs' Law should be settled through an account, a cash payment may still exclude the relevant amount from deductible costs.

6. Four practical examples

Example 1. A company receives an invoice issued on 20 December 2026 and pays it on 8 January 2027 into an off-list account. Because of the invoice date, the current PIT/CIT rules apply. VAT liability and the option to submit ZAW-NR must be assessed separately.

Example 2. An invoice is issued on 10 January 2027 and the buyer mistakenly pays an off-list account. That error alone should not deny a PIT or CIT cost, but joint VAT liability may still arise.

Example 3. A January 2027 invoice is subject to mandatory MPP but is paid by ordinary transfer. The cost is not automatically denied for PIT or CIT, but the buyer should assess the VAT surcharge and fiscal penal exposure.

Example 4. A business settles in cash a transaction that should be paid through a payment account. The amendment does not remove this restriction. The expenditure may still be non-deductible in the relevant part.

7. What does this mean for foreign-owned businesses?

A foreign parent often pays Polish subsidiary invoices through a group banking platform or shared service centre. The Polish finance function should ensure local rules for bank-account validation, identification of MPP invoices and ZAW-NR handling. Centralising payments outside Poland does not remove Polish tax duties.

The system should recognise the Polish NIP, VAT status and supplier account on the transfer order date.
Invoices subject to MPP require a PLN payment and the correct Polish bank message.
The procedure should assign responsibility for ZAW-NR and its filing deadline.
Exception reporting should distinguish PIT/CIT effects from VAT effects and include the invoice issue date.

For foreign-owned companies, this process is part of entering the Polish market.

8. What should be prepared before the end of 2026?

Keep white-list controls and mandatory MPP rules active.
Add the invoice issue date to the workflow as the transitional-rule criterion.
Separate system messages for PIT/CIT deductibility, VAT liability and MPP penalties.
Test payments made in 2027 for December 2026 invoices.
Update the ZAW-NR instruction and retain proof of the account check made on the transfer date.
Train accounting, treasury and payment approvers.

9. Frequently asked questions

Can a company stop checking the white list from 2027?

No. The amendment removes the PIT/CIT sanction, but joint VAT liability and the need to evidence due diligence remain.

Will ZAW-NR become unnecessary?

No. For invoices issued from 2027 it will no longer be needed to protect PIT/CIT deductibility, but it may still protect against joint VAT liability.

Will missing split payment have no consequences?

No. Automatic PIT/CIT cost denial will disappear, but VAT penalties and fiscal penal exposure may remain.

What about a December 2026 invoice paid in 2027?

The existing PIT and CIT rules apply because the transitional provision refers to the invoice issue date.

Do the new rules cover cash payments?

Not for the cost restriction. Payment without an account for a transaction above the statutory limit may still deny a tax cost.

10. Conclusion

From 2027, one payment error will no longer create parallel sanctions in income tax and VAT. The simplification is real but narrower than the phrase “end of sanctions” may suggest. Businesses should keep white-list and MPP controls while updating accounting treatment and exception reporting.

Review your company's payment and tax settlement procedures. Contact the inPL Group accounting team. Accounting services

Sources

This material provides general information and is not tax or legal advice. The effect should be assessed for the specific transaction, invoice, VAT status of the parties and payment method. Re-check the current legislation and official guidance before publication or implementation.