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In principle, all suppliers dealing with Polish customers have to record their bank account(s) in the so-called White List in Poland.  Based on the Polish law, the Polish customers must indeed make payments to a bank account available in said White List. If a customer pays to another bank account, there are tax consequences for him: the expense would not be regarded as a deductible cost and the customer would be jointly and severally liable with the supplier for the VAT due.

Changes in that matter have been introduced on 1 July 2020 and it is now easier for the customers to avoid these negatives consequences.

In order to minimize the consequences, the customer previously had to inform the Polish VAT Authorities that he made a payment to a bank account that wasn’t in the white list. This is done by means of a “ZAW-NR” notification (within 3 days following each transfer order).

As of 1 July 2020, a single notification is sufficient. It should be communicated to the Polish Authorities at the time of the first transfer of money only. In other words, it is no longer necessary to notify the Polish authorities for each and every payment to the same bank account.

Moreover, the deadline for the notification has be amended. It is now required to inform the Polish Authorities within 7 days following the first payment (instead of 3 days).