2025-04-02
Using ZAW-NR as „Last-Resort Lifeline” for Entrepreneurs
If you run business in Poland and make higher wire-payments exceeding PLN 15,000 to contractors (B2B), ensure the recipient’s bank account is listed in the official VAT taxpayer registry ( “white list”). Failure to verify this can jeopardise your CIT and/or VAT position. The "white list" was introduced to combat tax fraud in the so-called grey-zone, encouraging businesses to verify their contractor’s bank accounts. If the beneficiary’s account is on the “white list”, this means that he has notified it to the fiscal authorities.
If you run business in Poland and make higher wire-payments exceeding PLN 15,000 to contractors (B2B), ensure the recipient’s bank account is listed in the official VAT taxpayer registry ( “white list”). Failure to verify this can jeopardise your CIT and/or VAT position. The „white list” was introduced to combat tax fraud in the so-called grey-zone, encouraging businesses to verify their contractor’s bank accounts. If the beneficiary’s account is on the “white list”, this means that he has notified it to the fiscal authorities.
Otherwise, there is a risk that the authorities might not be aware of the need to monitor such account, thus making you an involuntary accomplice in potential tax fraud.
How to avoid the risk if such payment has already been made? Submit the ZAW-NR form!
Filing form ZAW-NR allows you to avoid negative CIT consequences, such as treating the expenses as non-deductible cost. Additionally, it protects you from joint liability for the contractor’s arrears on VAT related to your purchase .
What is ZAW-NR?
ZAW-NR is a notification to the tax office about a payment made to a non-listed account. It takes effect only when filed within 7 days from the first transfer to a given account.
When was ZAW-NR first introduced?
ZAW-NR form was introduced on January 1, 2020, as part of changes to income taxes (PIT and CIT) and VAT. Its primary purpose is to grant entrepreneurs a “last-resort lifeline” from the said negative consequences.
Who is it for?
Mostly Polish companies who want to keep their expenses tax-deductible and to avoid joint liability with the seller. However, also foreign companies might be interested in minimising the latter risk.
Restoring the deadline for filing ZAW-NR – is it possible?
Taxpayers only have 7 days to file ZAW-NR, starting from the date of their first payment to a non-listed account.
Unfortunately, this deadline cannot be extended, thus missing it may lead to serious tax consequences. On the bright side, once submitted, ZAW-NR provides protection for all future payments to the same account (even it is remains non-listed).
What if you miss the 7-days deadline?
There is no perfect solution, but here are two possible options that may help:
• Refund & Repayment – If the contractor is likely to have his account listed, ask him to return the original payment and then reprocess the payment once the account is “safe”.
• Refund & Payment to Another Account – If the contractor is unlikely to have any listed account, you might still ask him to return the payment, yet make the new payment to a different bank account (and file ZAW-NR withing 7 days from the second payment).
In option no. 2, avoid repaying to the same account as the original one, since this could be deemed an obvious circumvention of the rules.
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