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Payment to an Account Outside the “White List” – Tax Consequences for Businesses
- Paweł Gorzelec
- Aug 11
- 2 min read
Updated: Aug 13
In business, timely payment of invoices is essential – but so is ensuring the funds go to the right bank account. Since 2019, Poland has operated the “White List” of VAT taxpayers – an official register allowing companies to verify contractors and their bank account numbers.
Failing to transfer funds to an account listed on the register, especially for transactions over PLN 15,000, can result in serious tax consequences – including losing the right to deduct the expense for CIT/PIT purposes and being jointly liable for the supplier’s VAT arrears.
When must you pay to a “White List” account?
According to the law, payment must be made to an account on the register if:
the other party is a business entity,
the single transaction value exceeds PLN 15,000 (in PLN or equivalent in foreign currency at the NBP exchange rate from the day before the transaction).
The register is available here: VAT taxpayer search tool.
Consequences of paying to an unlisted account
If the transfer is made to a bank account not listed on the register on the payment date, the buyer:
cannot treat the payment as a tax-deductible expense (for the part paid this way),
may be jointly liable for the supplier’s VAT arrears.
If the payment is split into instalments, each is assessed separately.
How to fix the error – ZAW-NR
You can avoid penalties by filing the ZAW-NR notification with your tax office within 7 days of ordering the transfer.
Submitting ZAW-NR:
allows the expense to be deductible,
releases you from joint VAT liability.
Important:
The notification applies to the bank account, not the individual payment – once reported, you don’t need to repeat it for subsequent transfers to the same account.
Submit it online via e-Tax Office or in paper form.
Other ways to avoid sanctions
No penalties will apply if:
payment is made using split payment (mechanizm podzielonej płatności),
funds go to a specific type of bank/SKOK account meeting statutory conditions,
the invoice concerns imports, intra-EU acquisitions, or reverse-charge transactions.
Summary
Always check the contractor’s account before making payments over PLN 15,000. It’s a small step that protects your tax deductions and shields you from VAT liability for your supplier’s mistakes.
Taxenbach tip: Implement a company rule – always verify the account number before high-value payments. Prevention is much cheaper than fixing mistakes.
Legal basis:
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