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SAF-T Requirements for Poland

The Polish tax office requires two additional pieces of data to be recorded on VAT returns for certain transactions, this is to fulfill the Standard Audit File for Tax (SAF-T) requirements. This applies to VAT returns filed from 1 November 2020 onwards and failure to provide the correct data can lead to hefty fines. Avalara has adjusted the AvaTemplate and Cost price list templates to include these new data fields so please ensure you have downloaded the latest versions of each template.

The updated templates can be downloaded here:

The majority of VAT Returns customers who file in Poland will not be affected by the SAF-T changes, but please review the details below carefully to make sure you aren't caught out.

Please note that when a SAF-T compliant VAT return is required, an additional expense may be incurred by customers.

Additional data requirements

In addition to the usual data you submit to Avalara, two additional items may be required:

  • GTU codes: Transactions for goods and services that fall under 13 specific categories must include a GTU code. The GTU codes cover goods such as alcohol, fuel, waste, and even some electrical components. Please review the full list in the table below.
  • Document codes: Certain types of transactions must be accompanied by a document code. There are six codes covering transactions such as cash register sales and non-billable sales. Please review the full list in the table below.

Transactions that do not meet the criteria above can be entered into the templates in the usual way, with the new fields left blank. Remember, it is your responsibility to provide accurate data – Avalara will not check or validate your GTU codes or document codes.

GTU codes

There are 13 GTU codes spanning from GTU_01 to GTU_13. A field for the GTU code is included in both the AvaTemplate and Cost price list. If you sell goods on Amazon, you must include the GTU code in the cost price list. More than one GTU code should be provided if the transaction falls into multiple categories.

GTU code



Supply of alcoholic beverages

Ethyl alcohol, beer, wine, fermented beverages and intermediate products as defined in the provisions on excise duty


Supply of oil and fuel

Goods referred to in Article 103(5aa) of the VAT Act, which have only the CN codes specified in that provision. These goods can generally be classified under:

  • aviation gasolines
  • certain motor gasoline
  • liquid petroleum gas (LPG)
  • gas oils
  • heating oils
  • jet fuel of the petrol type
  • paraffin type jet fuel
  • remaining gas oils
  • liquid fuels
  • biofuels
  • other goods referred to in Article 86(2) on excise duty, listed in Appendix 1 to that Act, irrespective of CN code.


Supply of heating oil

Other oils with CN codes from 2710 19 71 to 2710 19 99, excluding products with CN code 2710 19 85 (white oils, liquid paraffin) and plastic greases falling within the CN code 2710 19 99, lubricating oils of CN code 2710 20 90, lubricating preparations of CN heading 3403, excluding plastic lubricants of this heading.


Supply of tobacco

Tobacco products, dried tobacco, liquid for electronic cigarettes and innovative products within the meaning of the provisions on excise duty.


Delivery of waste

Only those specified in item 79-91 of Annex 15 to the VAT Act, i.e.:

  • wrecks for scrapping other than ships and remaining floating structures
  • glass waste
  • paper and cardboard waste
  • remaining rubber waste
  • plastic waste
  • non-hazardous metal-containing waste
  • hazardous waste containing metal
  • waste and scrap of electric cells and accumulators; spent primary cells, spent primary batteries, and spent electric accumulators
  • metallic secondary raw materials
  • secondary raw materials from glass
  • secondary raw materials from paper and board
  • secondary plastic raw materials
  • rubber secondary raw materials.


Supply of electronic devices

Electronic devices and parts and materials for them, exclusively specified in item 7-9, 59-63, 65, 66, 69 and 94-96 of Annex 15 to the VAT Act, i.e.:

  • emulsions for surface sensitization for use in photography; chemical preparations for use in photography (n.e.c.) – exclusively toner cartridges without a print head for automatic data-processing machine printers
  • typewriter ink, draft ink and other inks – exclusively ink cartridges without ink head for automatic data processing machine printers
  • plates, sheets, film, foil, tape and strip of plastics, not reinforced, laminated or combined with other materials – stretch foil exclusively
  • electronic integrated circuits – processors exclusively
  • computers and other automatic data-processing machines
  • memory units – hard disk drives (HDDs) exclusively
  • solid-state non-volatile storage devices – SSDs exclusively
  • phones for mobile networks or other wireless networks – exclusively mobile phones, including smartphones
  • video game consoles (of a kind used with a television receiver or standalone screen) and other appliances for playing games of skill or chance with an electronic display – excluding parts and accessories
  • digital cameras for photography and digital cameras
  • parts and accessories for photocopiers – exclusively cartridges with ink and print head for automatic data-processing machines, toner cartridges with print head for automatic data-processing machines
  • operating system software packages – SSDs exclusively
  • remaining application software packages – SSDs exclusively
  • other films and video recordings on disks, magnetic tapes, etc. – SSDs exclusively.


Supply of vehicles and car parts

Codes CN 8701 – 8708 and CN 8708 10.


Delivery of precious and base metals 

Those specified in item 1-3 of Annex 12 to the VAT Act and in item 12-25, 33-40, 45, 46, 56 and 78 of Annex 15 to the VAT Act.


Supply of medicines and medical devices

Medicinal products, foodstuffs for particular nutritional uses and medical devices covered by the notification obligation referred to in Art. 37av section 1 of the Pharmaceutical Law Act.


Supply of buildings, structures, and land


Provision of greenhouse gas emission trading

Provision of services in the scope of transferring greenhouse gas emission allowances referred to in the greenhouse gas emission allowance trading system Act.


Provision of intangible services 

Exclusively: consulting, accounting, legal, management, training, marketing, head offices, advertising, market, and public opinion research, in the field of scientific research and development works.


Provision of transport services and storage management 

Section H PKWiU 2015 symbol ex 49.4, ex 52.1.

Document codes

Certain types of transactions need to be accompanied by one of six document codes, these are described below. This code needs to be entered into the AvaTemplate.

If you are unsure whether your transactions fall within these definitions, please speak to a tax adviser with expertise in Polish VAT. Avalara does not provide tax advice.

Document code

Transaction type




An internal summary document containing sales from cash registers


Sale or purchase

Internal documentation. Examples include:

  • non-billable sales
  • exempt sales for which invoice was not issued
  • annual input tax adjustment



Invoice referred to in Article 109 section 3d of the VAT Act (invoice issued based on the cash register's receipt)



RR VAT invoice referred to in Article 116 of the VAT Act (purchases from flat-rate farmers)



Invoice issued by a taxpayer who is a supplier of goods or services and who has opted for the settlements on a cash basis specified in Article 21 of the VAT Act.

See also

An introduction to the Avalara VAT Returns service

Uploading data files to Avalara VAT Returns

Standard Audit File for Tax (SAF-T)

Nil VAT returns

FAQs and support