Split payment – the split payment mechanism

VAT taxpayers in Poland may or must use the split payment mechanism. This is regulated by the provisions of the VAT Acts. In specific cases and when the indicated conditions are met, this type of payment mechanism is mandatory for transactions exceeding PLN 15,000 gross. Find out what you need to know about split payment to use it consciously and in accordance with applicable regulations.

Split payment – what is the split payment mechanism?

The split payment mechanism (SPM), or split payment, is a procedure whereby payment for goods or services is made via a special transfer. This is the so-called transfer message, and part of the funds does not go directly to the recipient's account. The essence is that the transaction value is divided into the net amount and the VAT due. The net amount goes to the designated account, while the tax amount goes to the VAT account designated by them. Split payment is intended exclusively for VAT taxpayers and can be either voluntary or mandatory.

Mandatory split payment – from what amount in 2026?

In 2026, mandatory split payment applies to transactions whose value exceeds PLN 15,000 gross and which simultaneously meet both of the following criteria:

• both parties to the transaction (buyer and seller) are VAT taxpayers,
• at least one item on the invoice is included in the list in Annex 15 of the VAT Act.

If a given transaction is lower or does not meet both conditions simultaneously, using the VAT split payment mechanism is voluntary.

What goods and services does split payment cover?

The detailed list of goods and services covered by the split payment mechanism is contained in Annex 15 to the VAT Act. Among them are, in particular:

• construction services,
• waste recycling services,
• jewellery services and products,
• selected food products,
• chemical goods,
• car and motorcycle parts,
• computer equipment and software,
• energy raw materials (e.g. coal and fuel),
• machines and electrical devices, as well as their parts and accessories,
• precious and base metals,
• and others.

Every entrepreneur should carefully review the annex. In case of any doubts, we recommend contacting an official at the Tax Office, who will answer questions and indicate the correct interpretation of a given product or service. Based on many years of experience, our experts are also able to help you in this area.

How to make a payment using the split payment mechanism?

The split payment mechanism applies only to transactions on accounts or company accounts opened at a bank, or personal accounts at credit unions (SKOK) opened in connection with business activity. At the same time, they must appear on the VAT taxpayer register, known as the white list. If you make a payment to a personal account, it will not be processed. The payment is then made in the standard way without the need to provide a separate VAT account number. It turns out that this account is opened automatically by the bank or SKOK.

However, please note that split payment is made using the transfer message, which is a special type of transaction provided by financial institutions. In this message, you must specify:

• the VAT amount (or part thereof),
• the gross sales amount (or part thereof),
• the invoice number on the basis of which the transaction is being made,
• the counterparty's NIP number.

Make sure that all details, including the company name and account number, have been entered correctly. This will reduce the risk of a potential error in the transfer and ensure the funds reach the correct recipient.

When the funds arrive at the recipient's bank, their system will automatically split the total amount into the net portion and the VAT due, after which they will be credited to the appropriate accounts. It is the bank that is responsible for the proper accounting of the received funds in the recipient's company account and VAT sub-account.

What can the money accumulated in the VAT account be used for?

As already mentioned, with split payment, part of the funds ends up in a dedicated VAT account. They can then be used for:

• paying VAT due to the Tax Office,
• paying social insurance contributions,
• filing a VAT refund order due to an invoice correction,
• other tax liabilities, including interest for late payment,
• corporate income tax and advance payments on this tax,
• excise duty, including advance payments, daily instalments and interest,
• customs duties and interest,
• and others.

It is also possible to withdraw part of the funds from the VAT account to a standard company account, if those funds cannot be used for settlements with the Tax Office and other entities specified in the Act. In that case, an application must be submitted to the Tax Office for the release of these funds, and the tax administration authority has 60 days to make a decision.

What are the consequences of avoiding the use of split payment?

Entrepreneurs who avoid the mandatory use of split payment face significant financial penalties of up to 30% of the VAT amount. It is therefore worth becoming thoroughly familiar with the split payment mechanism and using it in accordance with the regulations.

Sources:

• https://www.frr.pl/news/1635/split-payment-na-czym-polega#anchor-2
• https://www.biznes.gov.pl/pl/portal/00227#1
• https://www.ey.com/pl_pl/insights/tax/split-payment-co-to-jest-mechanizm-podzielonej-platnosci
• https://jpk.info.pl/jpk-v7/split-payment-lista-towarow-uslug-zalacznik-15/