TRANSPARENCY OF PAYMENT
TRANSACTION SETTLEMENTS

Settlements with the use of the Split Payment mechanism are obligatory depending on whether they refer to goods and services specified in the list which constitutes Attachment no. 15 to the VAT Law.

No, there is no such obligation.

The payer that orders the Split Payment, specifies the gross payment amount and, as an additional information, the VAT amount included. Such a transfer is settled as one payment and only one message is transmitted between banks. On the basis of the contents of that message, amounts are divided into the “ordinary“ account and ”VAT account.” When applying the Split Payment, the ordering party will be also obliged to specify the VAT invoice number and the Beneficiary's fiscal code.

Split Payments is settled through transfer orders in the Elixir, Sorbnet, and ExpressElixir systems. It is also possible to settle through Direct Debit. Settlements with another bank are made for the gross amount.

No, the mechanism will apply only to payments made using the dedicated transfer message (Elixir, ExpressElixir, Sorbnet). The Split Payment will be available also to settlements using the Direct Debit.

Provisions of the Law refer only to companies, entities for which Banks will maintain VAT accounts. Banks will not maintain VAT accounts to settlement accounts of natural persons.

Banks will be obliged to open a VAT account for each entrepreneur which holds a settlement account or accounts. The Bank will open one VAT account to all settlement accounts held by the entrepreneur maintained in PLN.

From the VAT account, amounts due to the tax office can be paid (output VAT) as well as the VAT amount into the supplier's account (input VAT), on which the supplier received the VAT invoice. Furthermore, funds can be transferred to another VAT account of the same Customer in the same bank, provided that the Customer holds more than one VAT account.

In order to fulfil tax liabilities, a tax payment order to the Tax Office should be executed, on account of the selected tax liability, to debit the settlement account which is linked to the appropriate VAT account. Correct bookings that will debit the holder’s VAT account, will be made by the Bank’s operating systems. The same manner of execution is applicable to payment of contributions which ZUS (Social Security Office) is obliged to collect: a standard domestic transfer should be made, to debit the settlement account which the appropriate VAT account is linked to, and to the individual account of the payer maintained by ZUS. Correct bookings that will debit the holder’s VAT account, will be made by the Bank’s operating systems.

The VAT account can be supplied by VAT amounts paid by buyers of goods or services under the Split Payment, by payments resulting from invoice adjustments or a return of the excess input VAT by the Tax Office or by a transfer of VAT funds from another VAT account maintained in the same bank (own transfer). It is impossible to supply the VAT account using one's own settlement (current) account.

At the Customer's special request, the Bank will open more VAT accounts. 

No. VAT accounts can be maintained in PLN only and linked only to the settlement account or accounts maintained in PLN.

No, it will not be possible. The VAT account linked to the specific account will be opened in the bank where the settlement (current) account is maintained.

No, it is not necessary. Transfers, including the ones under the Split Payment mechanism, are sent between settlement accounts. It is the Bank that will split the amount receivable into the principal amount, to be transferred to the ordinary account, and the VAT amount, to be transferred to the VAT account. It will not be necessary to know the VAT account number of the supplier.

When the current account, to which the VAT account is assigned, is closed, to make the closure effective, it is also necessary to transfer the funds accumulated on the linked VAT account to another VAT account maintained by the Bank, or to the holder’s current account for further instructions regarding the funds. If the funds are transferred to another VAT account maintained by the Bank, consent of the Tax Office Manager is not required: the holder makes the operation independently as the so-called own transfer. To transfer funds from the VAT account to the holder’s current account, the so-called individual consent (decision) issued by the Manager of a Tax Office competent for the holder is needed. To this end, the holder must file a written request to the Tax Office for consent to such a transfer of funds. The Bank will transfer the funds from the VAT account to the specified current account maintained by the Bank only when it receives an authorised instruction from the Tax Office. Upon posting the funds, the holder can administer them in the current account and order the Bank to transfer them to a specified account in another bank, or withdraw them in cash.

If the customer holds more than one VAT account in the bank, VAT funds can be transferred into another VAT account in the same bank. To this end, the customer will have to submit a Split Payment order in which the settlement account linked to the VAT account which the customer wants to debit with the funds, is indicated as the account to be debited, and the other settlement account is specified as the account to be credited, linked to the VAT account which the customer wants to credit with the funds. The VAT amount indicated in the payment order should equal the payment amount. In this way, the funds will be transferred between the customer's own VAT accounts.

The execution of the outgoing Split Payment will be reflected by the following postings:

the linked VAT account will be debited with the VAT amount,

the settlement account will be first credited with the VAT amount and then debited with the gross amount of the Split Payment.

The execution of the incoming Split Payment will be reflected by the following postings:

the settlement account will be first credited with the gross amount and then debited with the VAT amount.

the VAT account linked to the settlement account will be credited with the VAT amount.

The statement of the VAT account / VAT transaction history is available in the BiznesPl@net system. In this application, the Customer has access to the list of VAT accounts, and details of the VAT account include information on settlement accounts that it is linked to.

No, only one VAT account can be linked to one settlement account. When a Split Payment order is submitted from a selected settlement account, the VAT amount will be posted to the VAT account linked to that settlement account.

No. For such payments, a standard domestic transfer should be used. In the Split Payment, it is necessary to specify the VAT amount which must be higher than PLN 0 and not higher than the payment gross amount.

Yes. A functionality of the electronic banking to service mass payments has been prepared to accept and handle the so-called packages that contain mass quantities of single Split Payment orders. Packages with mass orders can include nothing but Split Payment orders but it is also possible to combine ordinary orders and Split Payment orders in the packages. The Bank’s operating systems will appropriate select orders in the packages and transfer them to be settled in accordance with the ordering party’s instruction.

Yes. Split Payment will be available for internal payments.

There is no need to hold a positive balance in the VAT account to make a payment as a Split Payment. Should there be an insufficient amount, in part or in full, in the VAT account, the Bank will charge the missing VAT amount to the settlement account.

Such an order cannot be submitted/executed due to the lack of sufficient funds in the current account.

Having decided to make a Split Payment, the ordering party will pay for a  specific VAT invoice by specifying the gross amount of the transfer and separately, the VAT amount. The ordering party is also obliged to provide the tax identification number of the supplier of goods or services (the VAT invoice issuer). Additionally, the number of the VAT invoice related to the payment should be indicated. Also, any description of up to 33 characters can be added. In the BiznesPl@net system, a new screen (form) will appear to make the Split Payment.

From the formal point of view, an advance is documented by a VAT invoice only when it credits the supplier's account. In the classical perspective, first the payment is made and only then the advance VAT invoice is issued. Therefore, the Split Payment cannot be applied here as it requires a payment to be made on the basis of an invoice (the invoice number should be indicated when making the dedicated transfer).

Payments will be made only to debit the settlement (current) account. It will not be possible to make a payment order to debit the VAT account specified. The net invoice amount cannot be debited to the VAT account.

Payments received (incoming transfers) where the VAT account is indicated as the beneficiary's account, will be returned by the Bank to the payer's Bank.

If the Bank receives a Split Payment in favour of a person or entity that holds no VAT account, the Bank will be obliged to return such a payment to the payer's bank. Such a payment will not be executed.

In such a case, the Bank will debit the VAT account with an amount up to the account balance, and the rest of the VAT amount due will be debited to the settlement (current) account. In the event the VAT account balance is PLN 0, all the VAT amount specified in the Split Payment will be debited to the settlement account.

The Split Payments can be made in PLN only, from and to settlement accounts maintained in PLN in the territory of Poland. The settlement can be made only using dedicated messages in the Elixir, ExpressElixir and Sorbnet systems. Therefore, the Split Payment cannot be made in a foreign currency.

No. The Split Payment mechanism applies only to payments made using the dedicated transfer message (Elixir, ExpressElixir or Sorbnet) and only in PLN.

VAT accounts will be opened only as accounts linked to settlement (current) accounts maintained in PLN. The Bank will not open VAT accounts to foreign currency accounts. Therefore, there will be no option to make the Split Payment with a currency conversion from a foreign currency account. The Customer will first have to make a currency conversion to a PLN settlement account and only then make the Split Payment.

The information about the VAT account and its balance will be available through the view mode of the settlement account that the VAT account is linked to. The information will also be available through the view mode of the split Payment form and Tax Office payment liability form out of VAT settlement..

Split Payment transfers can be combined in transfer packages. One package can contain both Split Payments and other transfer types.

Yes, the Host To Host functionality includes handling Split Payment orders.

To transfer the VAT amount to the beneficiary, the VAT amount equal to the gross payment amount should be indicated in the Split Payment order. For example, where the gross amount of the invoice received is PLN 123.00, the invoice net amount is PLN 100.00 and the invoice VAT amount is PLN 23.00, PLN 23.00 should be entered in the “Kwota płatności” (payment amount) field and PLN 23.00 should be entered also in the “Kwota VAT” (VAT amount) field. In such a case, the amount of PLN 23.00 will be transferred, that is, only the VAT amount and as the VAT amount in the transfer.

Yes, entering the full number of the invoice, along with all the special characters used in the numbering, is obligatory. An incomplete invoice number provided when executing payments in the Split Payment formula may result in complications for the transfer payee.

Pursuant to the recommendation of the Polish Bank Association, in the event the invoice number is longer than 35 characters (i.e., the predetermined  maximum length of the invoice number field), excess characters of the invoice number should be entered in the subsequent field earmarked for a description/free text (the field marked in payment messages by the code word of /TXT/). For example, if an invoice number consists of 41 characters: "F1234567890123456789012345678901234567890," then the field containing the number of this invoice in the payment message will have the following form: /INV/F1234567890123456789012345678901234/TXT/567890, that is, after the code word of /TXT/, excess 36 – 41 characters of the invoice number will be entered.

Yes, you can. In the transition period, i.e. until a target form is adopted, such instructions should be made on a standard cash payment / transfer order  form WP (according to PN-F-01101: 2017-10). Due to a limited length of the form fields, i.e. the field kwota (amount) permits 12 characters while the field tytułem (title) - 2x 27 characters, pursuant to the recommendation of the Polish Bank Association, the form should be completed as follows(it’s example filling):

The data import/export mechanism will be supplemented by an option to handle Split Payment orders. The import and export templates for Split Payments will be created.

Both the import and export templates will contain data related to the payment of the gross amount and VAT, the specification that it is the Split Payment transaction, gross amount, number of the settlement account to be debited with the gross amount, number of the settlement account to be credited with the gross amount, VAT amount, the counterparty's tax identification number, VAT invoice number, and optionally, an additional text and reference number.

To date, the final formats of such files have not been determined yet. The file formats will be published soon.

You can make the Split Payment order. The net amount will debit the current account and the VAT amount will debit the VAT account linked to the settlement account from which the payment will be made.

No. The payment under a loan is made on the basis of a loan agreement and not a money settlement related to a bank account or invoice purchase which are subject to the Split Payment mechanism.