Split payment method

The split payment method (MPP) in a mandatory form for some transactions enters into force from November 1 2019.

MPP includes invoices for transactions that meet two conditions in total:

  • the transaction concerns the acquisition of goods and services listed in Appendix 15 to the VAT Act, which includes transactions for the purchase of goods and services mentioned so far in Annex 14, 13 and 11 of the VAT Act, covered by the reverse charge mechanism and joint and several liability, and inter alia parts and accessories for motor vehicles, coal and carbon products, electrical machinery and equipment, their parts and accessories,
  • the total receivable resulting from the invoice (ie the gross value of the entire invoice) exceeds the value of PLN 15.000,00.


  • An invoice documenting the sale of goods / services from Annex 15 for the amount exceeding PLN 15.000,00
  • Invoice documenting the sale of mixed goods / services (i.e. goods / services covered and not covered by Annex 15 to the VAT Act) with a total gross value above PLN 15.000,00 *

* The obligation to apply SPM applies only to the amount due for goods / services from of Annex 15irrespective of the gross value of this item.

Therefore, if the invoice amounts to over PLN 15.000,00, and although one item of the invoice concerns the sale of a good / service from Annex 15 for an amount of e.g. PLN 1.300,00, this item must be regulated using the split payment method. Nevertheless, the taxpayer - despite the lack of an obligation - may settle in MPP the entire value of such an invoice.


In order to settle several invoices by the split payment method, a bank transfer must meet the following conditions:

  • invoices are issued by one supplier,
  • invoices are issued within one month,
  • indication of the period for which the payment is made (instead of the invoice number) *.

* In the case of making advance payments, prepayments, advance payments made in whole or in part before the delivery of goods or the provision of services, the word "advance payment" should be entered in the content of the transfer.


The mandatory split payment method will not apply to:

  • invoices documenting the sale of goods / services from Annex 15 for an amount lower or equal to PLN 15.000,00,
  • invoices documenting the sale of mixed goods / services (i.e. goods / services covered and not covered by Annex 15 to the VAT Act) with a total gross value lower than or equal to PLN 15.000,00,
  • settlement of receivables covered by the SPM obligation by way of compensation,
  • settlement of amounts due for the performance of a public-law partnership agreement.


As a result of the introduction of the obligatory SPM, the provisions on reverse charge in domestic trade and the rules for issuing invoices in this regard are no longer applicable. In their place, invoices should be issued with the VAT rate appropriate for a given transaction. The words "reverse charge" are placed only on invoices with foreign partners that document WNT and WNU.

WARNING!! For invoices subject to the obligation to settle by means of the split payment method, there is an obligation to include the designation "split payment mechanism".


  • Quarterly VAT declarations may only be submitted by taxpayers who sold goods or services listed in Annex 15 in total for the value without VAT up to PLN 50.000,00 for each month in a given quarter or in the four quarters preceding it.
  • The obligation to submit monthly VAT-27 declarations has been lifted.


The funds accumulated on the VAT account may be used to pay VAT, PIT, CIT, social security contributions, excise duty, customs duties and late payment interest in the above-mentioned taxes. At the taxpayer's request, by means of a decision issued by the head of the Tax Office, the funds may be returned to the indicated settlement account at the bank.


The provisions on the reverse charge apply to transactions for the supply of goods / services from Annex 15 made:

  • before November 01, 2019, for which the tax obligation will arise or the invoice will be issued after October 31, 2019.
  • after October 31, for which the invoice will be issued before November 01, 2019.

Taxpayers who before November 01, 2019. submitted declarations for quarterly periods and lost this possibility from November 01, 2019. will be required to submit declarations for monthly periods starting from the settlement for January 2020.


For the seller:

No invoice mark 'split payment mechanism"Results in an additional tax liability of 30% of the tax amount for the supply of goods or the performance of the service in Annex 15. Avoiding sanctions is possible by:

  • issuing a corrective invoice by the seller or issuing a correcting note by the buyer,
  • if the buyer pays an incorrectly issued invoice in accordance with the SPM mechanism

ATTENTION!! The seller is obliged to correct the invoice issued without the required marking.

For the buyer:

Regulation of invoices covered by SPP without maintaining the SPP mechanism results in an additional tax liability of 30% of the tax amount for the purchased goods or services from Annex 15, shown on the invoice for which the payment will apply. It is possible to avoid sanctions by:

  • settlement by the seller of the entire tax amount resulting from the invoice, which will be paid without the SPM.

ATTENTION!! Invoices covered by the SPP and marked "split payment mechanism", settled without the SPM mechanism, do not constitute tax costs. The adjustment should be made by reducing tax costs or increasing tax revenues (in the case of taxation in the form of a lump sum on recorded revenues) in the month in which the payment was made without the SPM. Changes in CIT / PIT will become effective for the payment of liabilities from January 01, 2020. for invoices charging tax costs in 2020. The above changes in CIT / PIT will not apply to payments of liabilities made in 2020, the costs of which were included in the tax costs of 2019.

Odpowiedzialność joint and several buyers:

Odpowiedzialność the buyer's tax liability applies to transactions for the purchase of goods covered by Annex 15 in the event of suspicion of tax arrears with the seller. It applies in proportion to the tax attributable to the supply of goods to the buyer, but does not apply to the purchase of services covered by Annex 15 and to the acquisition of goods for which the taxpayer will pay using the SPM.

Link to Annex 15