VAT register and virtual, escrow and deposit accounts
This problem was the subject of parliamentary interpellation No. 32747, to which the Minister of Finance replied in letter PT8.054.5.2019.WLI.451E. The first issue regarding virtual accounts seems to be of particular importance. These accounts are in fact widely used by entrepreneurs supplying goods and services on a massive scale, such as mobile network operators or media providers. These entrepreneurs will not show virtual accounts in the VAT taxpayers register (due to their number). The Minister of Finance, in response to a question asked by deputies, stated that payments to virtual accounts that are assigned to the settlement account will be treated as payments to the settlement account, which is subject to notification to the tax office. However, virtual accounts themselves will not be subject to the obligation to report to the tax office for inclusion in the list.
Payments to escrow or deposit accounts are different. The Minister of Finance believes that the funds on these accounts are only secured until the contract is implemented. However, if the payment to the escrow and deposit account were confirmed by an invoice, the buyer may submit a notification to the head of the tax office competent for the issuer of the invoice about the payment made to the non-listed account and thus free himself from the negative consequences foreseen from 01.01.2020.
At the same time, the Ministry of Finance announced that it will discuss the issue of escrow and deposit accounts in separate tax explanations.