Ordinary payment for laptops creates split-payment exposure but not necessarily loss of input VAT

Summary

• A Polish business paid PLN 24,600 for four laptops by ordinary bank transfer even though the invoice was marked for mandatory split payment. The structured invoice was received through KSeF and payment went to the supplier’s white-list account, but the supplier refused to return the funds for repayment through MPP. [edgp.gazetaprawna.pl]
• Failure to use mandatory MPP can trigger a VAT additional liability and income-tax consequences, subject to statutory conditions and exceptions. It does not automatically establish that the underlying input VAT is non-deductible where the purchase is genuine and used for taxable activity, but it creates a separate compliance and penalty risk. [edgp.gazetaprawna.pl], [podatki.gov.pl]
• Accounts-payable controls should identify Annex 15 goods, test the statutory invoice threshold and block ordinary payment methods where MPP applies. Remediation should include immediate supplier contact, evidence of the attempted correction, an analysis of voluntary disclosure options and confirmation of the VAT and income-tax treatment. [edgp.gazetaprawna.pl], [podatki.gov.pl]

Extended article

A reported Polish case illustrates the different consequences that can follow when a purchaser fails to use mandatory split payment.

On 3 August 2026, an active VAT taxpayer purchased four laptops for a total gross amount of PLN 24,600, including PLN 4,600 of VAT. The laptops were trading stock used in an activity generating taxable sales. The supplier issued a structured invoice through KSeF containing the words “mechanizm podzielonej płatności.” The buyer received the invoice through KSeF on the same day. [edgp.gazetaprawna.pl]

On 5 August, the buyer paid the full amount to the supplier’s account appearing on the VAT white list, but used an ordinary transfer. The supplier subsequently declined to refund the money so that the payment could be repeated using the MPP bank message.

Mandatory MPP generally applies to PLN-denominated B2B payments where the statutory value threshold is met and the invoice covers goods or services listed in Annex 15 to the VAT Act. Laptops are within the relevant electronics category. Under MPP, the bank routes the VAT component to the supplier’s VAT account and the remaining amount to its settlement account. [podatki.gov.pl]

Paying a white-list account addresses a separate compliance rule. It does not cure failure to use MPP. The purchaser may face an additional VAT liability calculated by reference to the VAT attributable to the Annex 15 items. Separate income-tax provisions may restrict deductibility of the relevant expenditure when mandatory split payment was omitted, although the precise outcome depends on the statutory remediation provisions and the facts.

At the same time, the input VAT deduction should be distinguished from the MPP sanction. If the transaction is genuine, the buyer holds a valid structured invoice and the laptops are used for taxable activity, the conditions for input VAT deduction may still be met. The payment-method breach must be analyzed separately rather than treated automatically as a denial of the underlying deduction.

Recommended action: configure the payment system to read the MPP flag from KSeF, identify Annex 15 lines and prevent release through an ordinary transfer. For an existing error, retain the supplier correspondence, prepare the VAT and income-tax assessment, and consider whether a voluntary-disclosure or other protective filing is appropriate.

Read the source article in Dziennik Gazeta Prawna and review the official Polish split-payment guidance. The source article is largely behind a subscription wall, so only publicly available details have been used.

---

---