Found a lost purchase invoice? How to book it correctly in Poland

Finding a purchase invoice some time after it should have been booked is one of the most common situations business owners face in day-to-day bookkeeping. It usually concerns invoices for periods for which income tax advances and VAT have already been paid. Invoices also sometimes reach us late for reasons beyond our control. This raises a natural question: can a purchase invoice found late still be booked correctly, and what are the tax consequences?

Booking forgotten or delayed invoices has to be analysed on two legal levels. The first is the rules on value added tax (VAT); the second is the income tax rules (PIT (personal income tax) or CIT (corporate income tax)). Each has its own rules and deadlines, which you must follow strictly to avoid problems with the tax authorities.

Rules for booking invoices found late for VAT purposes

Active VAT payers have specific options for deducting input VAT from invoices found after the period in which they should originally have been booked. The basic rule is that VAT can be deducted in the period in which the tax obligation arose on the seller's side, but the law also provides additional settlement periods in which the deduction can be made.

Active VAT payers who settle monthly can deduct VAT in one of the three settlement periods following the period in which the right to deduct arose (Article 86(11) of the VAT Act). In practice this gives four months to make the deduction correctly. Taxpayers who settle quarterly have two further settlement periods, which gives three quarters in total to deduct VAT.

Here are some practical examples. If a business that settles VAT monthly received an invoice in February, forgot to book it and only found it in April, it can still book it. The VAT from that invoice can be entered in the VAT purchase register in February (the month of receipt) or in March, April or May (the three following settlement periods).

With quarterly settlement the situation is similar, but the periods are longer. A business that received an invoice in January (first quarter) and found it in April can book the VAT in the first, second or third quarter of the tax year.

After these deadlines, the deduction is still possible by correcting the return (JPK_V7 (VAT return with records, SAF-T file)) for the period in which the right to deduct arose, or for one of the three (for quarterly settlement – two) following periods, but no later than within 5 years counted from the beginning of the year in which that right arose (Article 86(13) of the VAT Act). This lets you fix errors or make up for past omissions.

Cost-recognition methods in income tax

For income tax purposes, the cost-recognition method the taxpayer uses is crucial. Businesses keeping a KPiR (tax revenue and expense ledger) can choose between two methods: the simplified method or the accrual method (Article 22(6) of the PIT Act). The choice directly affects how invoices found late are booked.

Under the simplified method, costs should be recognised when they are incurred. The date a cost is incurred is the date the invoice or other accounting document, such as an insurance policy or a contract, was issued. This method does not split costs into those directly and indirectly related to revenue, which makes bookkeeping much simpler.

The accrual method requires a more detailed approach to booking costs. The basic rule is to recognise costs in the year to which they actually relate, splitting them into direct and indirect costs. Direct costs, such as purchases of goods for resale, should be recognised in the tax year in which the corresponding revenue was earned.

Under the accrual method, indirect costs are recognised on the date they are incurred, i.e. on the date the invoice or other accounting document was issued (Article 22(5c) and (6b) of the PIT Act). If indirect costs relate to a period longer than the tax year and it is not possible to determine what part relates to a given year, the costs must be split proportionally according to the length of the periods they relate to.

Deadlines for booking invoices found late

For income tax purposes, an invoice can, as a rule, be booked on its issue date or in a later period, but with an important limit: the end of the tax year – costs are deducted in the tax year in which they were incurred (Article 22(4) of the PIT Act). This means that the cost shown on the invoice – the net amount for active VAT payers or the gross amount for VAT-exempt taxpayers – should be booked in the year to which it relates.

Here is a practical example. A business owner who received an invoice for office supplies in October, forgot to book it and only found it in December can still book it correctly. The condition is that the expense meets the definition of a tax-deductible cost and is connected with the business.

You can book an invoice found late until the end of the tax year. After that, booking becomes much more complicated: the cost is recognised in the year in which it was incurred, and the annual tax return for that year is corrected (Article 81 of the Tax Ordinance Act (Ordynacja podatkowa)), which means extra obligations.

Practical procedures for booking forgotten invoices

How you book an invoice found late depends on whether it was found before or after the tax period was settled. If the invoice was found before the period was closed, the procedure is fairly simple: book it according to its issue date, keeping your entries in chronological order.

The situation is much more complex when the invoice turns up after the settlement period has closed. In that case the business must check whether it is still within the deadlines set by the VAT and income tax rules. If so, for the sake of good order it is recommended to book such invoices on the first day of the month in which they were found.

This approach has a practical justification. It allows businesses to avoid correcting returns already filed and JPK files already sent. This keeps tax settlements continuous without extra administrative complications.

Obligations related to the JPK_V7 file

Active VAT payers must submit monthly JPK_V7 files, the scope of data of which is set out in the regulation of the Minister of Finance, Investment and Development of 15 October 2019 (Journal of Laws (Dz.U.) 2019 item 1988, as amended). One of the key elements of this file is the invoice issue date, which means businesses must report in JPK_V7 the actual date shown on the purchase invoice. If the details on such an invoice are wrong, a correction note in KSeF can help.

This requirement has important consequences for booking invoices found late. Even if an invoice is booked in a period later than its issue, the actual issue date must be shown in the JPK_V7 file. This means you need accurate records of the issue dates of all accounting documents.

The JPK_V7 structure also requires other important information, such as:

1. The invoice number as shown on the document
2. The date the seller issued the invoice
3. The date the buyer received the invoice
4. The net value and the amount of input VAT, split into purchases of fixed assets and of other goods and services
5. Special markings, e.g. "MPP" (split payment mechanism) or "IMP" (import of goods)
6. The supplier's identification number (NIP (tax identification number)) and name

Differences in booking dates for VAT and income tax

When booking invoices found late, it is particularly important to distinguish between the booking dates for VAT and for income tax. These dates may differ because the two tax systems follow different rules.

For VAT, what matters is the date the document was received and the option of booking it in one of the following settlement periods under the rules described above. The VAT booking date may therefore differ from the date of booking in the KPiR.

For income tax, what matters is the date the cost was incurred and the tax year to which the cost relates. In practice, this means that an invoice found late can be booked in the KPiR on the date it was found (if this falls within the tax year), but in the VAT register on the date allowed by the VAT rules. A template for amending cost entries can be found in our article on the cost correction document.

A business owner running a trading business received an invoice for legal services in October, but filed it in the wrong folder by mistake. He found the invoice in December of the same year. For income tax purposes he could book the cost in December, as it was still the same tax year. For VAT purposes he could deduct the input VAT in October, November, December or January of the following year.

Consequences of missing the booking deadlines

Missing the deadlines set by tax law for booking invoices found late has financial and legal consequences. For VAT, once the deadlines in Article 86(11) of the VAT Act have passed, the deduction is only possible by correcting the return, and after 5 years counted from the beginning of the year in which the right to deduct arose, that right expires (Article 86(13)), which directly increases the business's tax burden.

Losing the right to deduct VAT is particularly painful with high-value invoices. The business then has to cover the VAT from its own funds, as it cannot deduct it from output VAT. Until that happens, you can use a correction of the return, but it involves extra formalities, and during a tax audit or tax proceedings the right to correct is suspended within their scope (Article 81b of the Tax Ordinance Act).

For income tax purposes, costs are deducted in the tax year in which they were incurred (Article 22(4) of the PIT Act), so a cost from an invoice for a closed year does not move to the following year. It is recognised in the settlement for the year in which it was incurred, by correcting the annual tax return (Article 81 of the Tax Ordinance Act). Once the limitation period has expired (as a rule 5 years from the end of the year in which the tax payment deadline passed – Article 70 § 1 of the Tax Ordinance Act), a correction is no longer possible.

Documenting the booking process

Properly documenting how invoices found late were booked is crucial for keeping your records transparent and avoiding problems during any tax audits. The documentation should include all relevant information about the circumstances in which the invoice was found and the reasons for the delay in booking it.

It is advisable to prepare an internal memo or other internal document containing:

• The date the business received the invoice
• The date the invoice was actually found
• The reasons for the delay in booking
• The booking date in each register
• The legal basis for the accounting treatment applied

Pay particular attention to keeping your books in chronological order. If an invoice is booked in a period later than when it was received, this should be clearly stated in the description of the entry. The description should include the actual date the document was received and the reason for the late booking.

Impact on financial reporting

Booking invoices found late directly affects a company's financial reporting. Costs recognised late may affect the financial result of the period in which they were booked, which can matter when contractors, banks or other stakeholders assess the company's financial standing.

For entities preparing financial statements under the Accounting Act, late booking may require adjustments to the financial statements or disclosures in the notes. This is particularly important for significant amounts that may affect the assessment of the entity's assets and financial position.

Businesses using simplified forms of record-keeping should also be aware of how late bookings affect their tax settlements. Concentrating costs in one period may affect income tax advances and the company's cash flow.

The most common mistakes when booking invoices found late

In accounting practice there are several typical mistakes when booking invoices found late, which can lead to problems with the tax authorities. Knowing these mistakes helps you avoid them and keep your records correct.

One of the most common mistakes is booking an invoice with the date it was found instead of the date it was received. This can cause problems with deducting VAT, especially if the statutory deadlines are exceeded. The correct practice is to book it with the date of receipt, but in the period in which it was found, with an appropriate description of the entry.

Another frequent mistake is failing to distinguish between the booking dates for VAT and for income tax. Business owners often book an invoice with the same date in all registers, which may be incorrect under tax law. Each register has its own specific requirements that must be taken into account.

Booking invoices without checking whether they still fall within the statutory deadlines is also problematic. Some business owners wrongly assume that any invoice found late can be booked regardless of how much time has passed. In fact, missing the deadlines may mean losing the right to deduct VAT or to recognise the cost.

IT systems and booking invoices found late

Modern accounting systems offer features that make it easier to book invoices found late correctly. Most programs let you distinguish between the invoice issue date, the date of booking in the KPiR and the date of booking for VAT, which is essential for settling taxes correctly. We rely on this distinction every day when keeping clients’ books as an accounting firm in Warsaw.

When booking invoices found late in IT systems, pay particular attention to:

• The invoice issue date as shown on the document
• The date of booking in the tax revenue and expense ledger
• The date of booking in the VAT purchase register
• An appropriate description of the entry
• Keeping chronological numbering

Accounting systems often let you generate reports showing invoices booked late, which makes it easier to control accounting processes and identify areas for improvement. Such reports can also be useful when preparing for a tax audit.

Frequently asked questions