The White List is a register of taxpayers which is in place since 09.2019 (available on the website: https://www.podatki.gov.pl/wykaz-podatnikow-vat-wyszukiwarka). It contains information about taxpayers for a selected day, no earlier than the 5-year period preceding the year of verification. The list is updated once every day except weekends and public holidays.

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The White List includes information on:

  • the name of company / individual,
  • VAT identification number, if assigned,
  • the company’s / individual status regarding VAT registration or removal,
  • the REGON identification number, if assigned,
  • the number in the National Court Register, if assigned,
  • the address of the registered office,
  • the address of the fixed establishment or residence for individuals,
  • bank account numbers (foreign bank accounts are not visible in the White List, also when they were reported to the tax office),
  • dates of VAT registration (in case of retroactive VAT registration, past data will not be visible), refusal of registration (with legal basis), removal from the register (with legal basis), and reinstatement (with legal basis).

The White List is important tool to check:

  • clients’ VAT status – crucial element of internal due diligence process,
  • numbers of supplier’s bank accounts – this verification is a must before a wire is executed (details below).

In Poland payments exceeding value of PLN 15 000 should be made via bank transfer with use of bank account number mentioned on the White List (also when transaction is split into several smaller payments). When payments are made to an account other than indicated on the White List, the following tax consequences will arise jointly:

  • expense cannot be treated as tax deductible cost from income tax perspective (it’s crucial for Polish residents),
  • purchaser bears joint liability for VAT obligations of the supplier.

If payment is made to a bank account not included in the White List, taxpayer can avoid the sanctions by submitting to the tax office the ZAW-NR form within 7 days from the transfer’s order date.