The entry into force of the mandatory KSeF (National e-Invoice System) will require real estate owners to adapt their accounting systems and invoicing processes. Real estate companies that cooperate with an external property manager will have to re-establish the tenant invoicing process.
ALERT! The Ministry of Finance has postponed entry of the obligatory KSEF into force. Read more here.
Issuing a structured invoice, with few exceptions, will only be possible in real-time. It will not be feasible to issue an invoice with a date other than the current one. Additionally, each invoice issued in KSeF will be immediately visible to tenants.
All domestic entities and foreign companies that have a permanent place of business for VAT purposes in Poland (fixed establishment / VAT FE) will be obliged to use KSeF. This means that foreign entities that own real estate in Poland will also, in some cases, be obliged to invoice tenants using KSeF.
Collaboration with property manager
Considering that a structured invoice must meet the technical requirements of logical structure, every taxpayer must confirm with the property manager that their billing system complies with KSeF requirements. It is also crucial to establish:
- The person who will have access to the KSeF Application and manage KSeF permissions
- The detailed scope of permissions granted to the property manager
- The procedure for invoicing tenants, including the provision of additional documents, such as attachments to invoices (protocols, specifications, etc.)
Proper implementation of KSeF will require the following steps::
- Determining the person with access to the KSeF Application and managing permissions
- Submitting a notification (ZAW-FA) to the tax office
- Configuring permissions in KSeF
- Generating a token and transferring it to the property manager.
A token is a 64-digit string of characters assigned to a specific entity and a specific scope of rights. It is a special way of logging in to the KSeF system. It ensures communication between external systems (invoice issuing program) and the KSeF application.
KSeF Aplikacja | Tokeny | Faktury | Video available only in Polish
Acceptance of invoices by tenants in KSeF
If the property owner issues sales invoices in KSeF, they will become automatically visible to tenants, with the option of downloading and posting them. However, the KSeF system does not provide for any procedure for their acceptance by the tenant. This also means that any additional communication with the tenant will have to be conducted outside the KSeF system. For example, in the event of incorrect identification of the buyer, incorrect amount or other errors on the invoice, it is necessary to act outside the KSeF system, i.e. the tenant should contact the property manager to clarify the situation and issue an appropriate correction invoice.
Once the invoice is issued in KSeF, there are no contraindications to sending it to the tenant in the form of a printout, e.g. sending it by e-mail in the form of a PDF file
KSeF does not enable the transfer of any additional documents to the buyer, such as specifications, protocols, orders, etc. These additional documents will have to be made available to the buyer in another way, e.g. by e-mail in the form of a PDF file. It will be important to link these additional documents with the issued structured invoice.
Scope of property manager’s permissions
The issue of the scope of permissions granted to the property manager needs careful consideration. It seems that the optimal solution would be to grant them permissions to issue sales invoices and send them on behalf of the taxpayer to KSeF, without the ability to retrieve purchase invoices.
The matter of retrieving purchase invoices is crucial and requires separate arrangements, especially for taxpayers owning multiple properties and cooperating with several property managers. It should be noted that the KSeF system allows the retrieval of all purchase invoices issued for a given taxpayer (based on NIP), without the possibility of prior segregation. The person with permissions to retrieve (view) purchase invoices will have access to all cost invoices
Our support
Find out how we can help with the implementation of the KSeF system and other tax and accounting aspects of running a real estate business in Poland.
