Taxpayers currently do not know how to behave in situations of less typical payments above PLN 15,000 gross, when it is necessary to use a transfer to a taxpayer's account indicated in the „White list”
The first problem is payment to virtual accounts, which appear when paying for e. g. media. They are not accounts within the meaning of the Banking Law and do not appear on the „White list”. In this case, the Deputy Minister of Finance, responding to Parliamentary Question No. 32747, stated that such payments will be treated as payments to the settlement account to which they are assigned.
Another issue is payment to a deposit or trust account. In this case, in the light of today's regulations, the best solution is to notify such a payment within 3 days of the transfer order to the tax authority (in accordance with Article 117 ba of the Tax Ordinance). The same applies to cession accounts. Minister of Finance and in this respect announced that it will make changes in the law by January 1, 2020.
In the opinion of Ministry of Finance, however, payment via credit card or electronic payment intermediaries (PayPal type) significantly identifies the final bank account to which the payment is made. Therefore, a taxpayer making such payments exposes himself to income tax consequences. Moreover, in this case there may be problems with notifying such a transfer in accordance with Article 117ba of the Tax Code. The Ministry of Finance promised to amend the regulations in order to eliminate the problems by January 1, 2020.
The last point is the number of admissible queries, the „inputs" to the „white list".The current API allows 10 queries to be submitted for up to 30 entities at the same time, giving a total of 300 entities per day. For large taxpayers, this could be a problem. Ministry of Finance announced a work to increase productivity.