For our Client from the automotive industry, we have obtained a positive VAT interpretation regarding the proper:
In connection with ongoing interpretation difficulties and the introduction of additional obligations regarding the markings on invoices and the proper marking of JPK files, tax adviser Iwona Jacieczko submitted a request for an individual interpretation to the Director of the National Fiscal Information. The application asked whether the service of servicing and repair of cars and the service of repairing vehicles after damage is a comprehensive service, and used parts, which are necessary to perform the above-mentioned services, should be specified on the invoice in separate items as the subject of sale. The scope of the request also covered the issue of the obligation to include the “split payment mechanism” (MPP) annotation on the invoice and marking the JPK_V7M file with GTU and MPP codes.
On 7 April 2021, the tax authority fully shared the standpoint of our tax advisor, holding that the services performed in the garage, which include the materials used and labour, should be treated as comprehensive provision of services for VAT purposes, which are not subject to the obligation to apply the “split payment mechanism”. The Director of National Fiscal Information pointed out that if only a service is the subject of the sale, then only the service should be indicated on the invoice as the subject of the sale. However, the costs of labour and materials used may constitute additional information. If we are dealing with comprehensive provision of services, including auxiliary services or/and materials, then the GTU codes of individual services and the MPP designation should not be indicated in the records part of the JPK-V7M file.
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