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As the governments’ announcements on VAT measures related to the COVID-19 epidemic outbreak continue to unfold at such great speed, here is our second summary of the recent developments. This is current as of the 30th of March.

For many countries there is uncertainty as to whether the below measures apply only to locally established businesses or have they been extended to non-resident companies. Essentia is investigating this on a country by country basis and we will publish the relevant updates shortly.

  • ITALY – Italy has not implemented any further VAT measures apart from those outlined in our previous newsletter of the 17th of March. Moreover, it is uncertain whether or not those measures that have already been announced can apply to non-resident companies.
  • SPAIN – no further announcements have been made by Spain since our previous newsletter of the 17th of March.
  • GERMANY – the German tax authorities have extended the VAT deferment period until the end of 2020.
  • AUSTRIA – in addition to a payment plan provisions outlined in our newsletter of the 17th of March, the deadline to submit the annual VAT return for 2019 period has been extended from the 30th of June 2020 to 31st of August 2020.
  • FRANCE – as it stands at the moment there are no specific VAT measures approved in France;
  • UK – according to the latest (of the 26th of March) HMRC’s guidance, both resident and non-resident businesses that are registered for UK VAT will have an option to defer their VAT payment due for the period 20 March – 30 June 2020 until the 31st of March 2021 (at the latest). Businesses paying by direct debit should cancel their direct debit orders with their banks. Note that these measures do not cover VAT MOSS payments. Please follow the link for full HMRC’s guidance: https://www.gov.uk/guidance/deferral-of-vat-payments-due-to-coronavirus-covid-19
  • IRELAND – in addition to the VAT measures outlined in our newsletter of the 17th of March, Ireland suspends all VAT debt enforcement activities until further notice.
  • POLAND – in addition to the VAT measures outlined in our newsletter of the 17th of March, Poland announced that the interest normally charged on the tax arrears will be temporarily abolished. Other VAT positions within the approved ‘anti-crisis shield’ include postponing the go-live date for the combined SAF-T file with the VAT returns for large companies from the planned 1st of April onto the 1st of July 2020 and the application of the new VAT rates matrix from the planned 1st of April onto the 1st of July 2020 as well as extension of the deadline for submitting a notification of payment to a bank account of the supplier not included in the Whitelist from 3 days to 14 days.
  • SWEDEN – the measures reported in our newsletter of the 17th of March can be backdated to January 2020 period.
  • DENMARK – as part of the Danish id package, businesses that settle VAT monthly received a 30-day extension of the deadline to pay the VAT whereas business settling VAT on a quarterly basis the payment for the first two quarters of 2020 can be combined and made by the 1st September 2020. Any businesses on a bi-annual frequency can pay the VAT for both half-yearly periods in a combined payment to be made only by the 1st of March 2021. For further details, please follow the link (in English): https://skat.dk/skat.aspx?oid=16900&lang=us
  • NETHERLANDS – the Dutch tax authorities may grant a 3-month VAT payment holiday upon receiving an application from a business struggling with its cashflow due to the COVID-19 crisis. Such applications can even be made by the companies over a telephone as far as the 3-month payment extension is concerned. If a business requires some a payment extension beyond 3 months, a written motivated application is required. In addition, the authorities are reducing the interest rate for such payments from 8% to 0,01%. Moreover, some extra VAT relief on customer bad debts related to the COVID-19 crisis are going to be granted and businesses in a regular VAT refund situation may switch from the quarterly VAT return filing frequency into the monthly returns to improve their cash flow.
  • SWITZERLAND – The Swiss tax authorities are going to allow the affected businesses to defer their VAT payments with no interest charge until the end of 2020.
  • NORWAY – the deadline for payment of VAT for January-February 2020 period has been postponed from the 10th of April to the 10th of June 2020. Moreover, the tax administration will not impose enforcement fines for late submission of the VAT returns. In addition to that, VAT rate for passenger transport, accommodation, public broadcasting as well as access to cinema, sporting events, amusement parks and adventure centres will be reduced from 12% to 8% from 1 April to 31 October 2020. Link to the Norwegian tax authorities’ announcement can be found here (in English): https://www.skatteetaten.no/en/package-of-measures-in-connection-with-the-coronavirus-situation/#value-added-tax-vat
  • CYPRUS – the measures reported in our newsletter of the 17th of March may now be reconsidered by the Cypriot government.
  • JAPAN – Japan may be reconsidering the implementation of the consumption tax measures, which were outlined in our newsletter of the 17th of March.

If you have any queries on the above, please get in touch with either your regular Essentia or Quipsound contact, or alternatively Marta Gałązka (+44 203 713 3535; marta.galazka@essentiaglobalservices.com)

Here is a summary of some emergency VAT measures to combat the financial impact of this pandemic, current as at 17 March 2020:

ITALY

  • The Italian Ministry of Finance announced on Friday, 13 of March that all the VAT payments due by March 16, 2020 will be postponed. Now it looks like the VAT payments for small businesses (with annual turnover below EUR 2m) will be postponed until 31st of May 2020 whereas for the remaining taxpayers the payments will be deferred until the 20th of March 2020. Moreover, all VAT declarations filings are to be postponed until the 30th of June 2020, including the Annual VAT Return for 2019 period. Businesses can apply for a 5-month payment plan.

SPAIN

  • Last week the Spanish Tax Agency published on their website a statement about the extension of the deadlines in VAT procedures. The Spanish Tax Agency also published on their website some provisional instructions on applying for a VAT deferral in accordance with the Royal Decree of 12 March foreseen for SMEs and professionals (with the last year’s turnover below EUR 6m), i.e. automatic 6-month VAT payment deferral will be granted for the VAT returns with a filing deadline between 13 March – 30 May 2020 and resulting with a VAT payment of up to EUR 30k. In addition, no late payment interest will be due for the first 3 months of a delay in payment. Link to the Spanish Tax Agency’s announcement can be found here:

https://www.agenciatributaria.es/AEAT.internet/Inicio/_componentes_/_Le_interesa_conocer/Instrucciones_provisionales_para_solicitar_aplazamientos_conforme_al_Real_Decreto_ley_7_2020__de_12_de_marzo_.shtml

GERMANY

  • The German tax authorities are offering a possibility to apply for delayed VAT payments as of the 13th of March 2020.

AUSTRIA

  • Application can be made to the tax authorities to postpone payment of VAT or payment via instalments. Application can also be made for reduction/waiver of late payment interest.

FRANCE 

  • Businesses can apply for a suspension of their tax payments due in March 2020.

UK

IRELAND 

POLAND

  • On the 11th of March 2020 the Polish Ministry of Finance informed that entrepreneurs who, due to the coronavirus, will have problems paying their taxes in a timely manner can apply for a reduction/relief or waiver/remission of arrears. Further detailed support should be announced by the Ministry of Finance in due course. In addition, the go-live date for the implementation of the combined SAF-T file with the VAT returns for large companies (the details of which Essentia provided to its readers in our February 2020 VAT Life publication) will be postponed from the 1st of April 2020 onto the 1st of July 2020. Moreover, the tax authorities are also to make the VAT refunds quicker. For full details about the proposed ‘shield package for companies’ follow this link: https://www.gov.pl/web/koronawirus/pakiet-oslonowy-dla-firm-w-zwiazku-z-koronawirusem

SWEDEN

  • The government is proposing an opportunity for temporary deferral with payment of VAT which is proposed to enter into force on April 7. The deferral period may be set for a maximum of one year.

NETHERLANDS

  • The government has announced that the Dutch tax authorities will grant a deferral of payment for any VAT if a company will motivate in writing that it has run into financial issues due to the coronavirus. As soon as the tax authorities receive such a request, they will put the collection of tax on hold.

CYPRUS

  • Cypriot government announced a temporary reduction of the standard VAT rate from 19% to 17% for 2 months and bringing down the reduced rate of 9% (applicable mainly to hotel accommodation, restaurant and catering services or domestic passenger transport) to 7.5% for 3.5 months.

JAPAN

  • Japan is considering temporarily lowering its Consumption tax rate from 10% to 5% on top of delaying the filing and payment deadlines by 1 month until April 2020.

CHINA

  • The country where the first cases of the coronavirus epidemic were detected has put some extensive measures in place to overcome the crisis, e.g. expanding temporarily the scope of the VAT exemption for goods and services needed to combat the effects of the virus, exempting temporarily from VAT all small-scale VAT payers located in Hubei Province or extending monthly VAT returns filing deadline for February and March 2020 periods by 2 weeks and 1 week, respectively.

Not driven by the crisis, but nevertheless extremely timely, is a European Court of Justice case concerning remote consultations with Doctors (which may become much more popular in the coming months).

The case related to a German company X-GmbH providing medical advice to insured persons and running patient support programmes for those suffering from chronic or long-term diseases. The medical consultations were provided over a healthcare telephone line, supported by an on-line assessment which allowed the consultant to put the patients’ situation into a medical context before providing the advice. The German authorities felt that this remoteness brought the service out of the VAT exemption for medical care. However, the CJEU held that the main criterion for determining whether or not the medical services could be exempt from VAT is whether those services pursue a ‘therapeutic aim’ regardless of the place or means of providing of such services. More details of the case can be found here .

As of the 1st of January 2020 a package of the so-called 4 ‘Quick Fixes’ came into force. One of the quick fixes was the Pan-EU simplification rule for call-off stock transactions. As our readers may know from reviewing our January newsletter, the application of the call-off stock simplification is conditional upon fulfilling certain requirements, one of them being to report in the recapitulative statement (EC Sales List) the VAT identification number of the intended acquirer.

Due to the fact that the existing EC Sales List forms do not allow reporting just the customer’s VAT number without entering the value, EU Member States are either amending their current forms or, alternatively, introducing some additional codes in the indicator columns/boxes for the purposes of the new call-off stock reporting obligations.

As an example, please find below the link to the UK tax authorities guidance on how to fulfil the company’s reporting obligations on the EC Sales List under the call-off stock arrangements using the three new codes that they introduced for these purposes in the indicator column: https://www.gov.uk/guidance/vat-how-to-report-your-eu-sales#call-off-stock

Poland – changes coming into force as of 1 April 2020

As of the 1st of April 2020 a number of changes will come into force in Polish VAT, namely:

  • Replacement of the currently separately submitted VAT returns (VAT-7 and VAT-7K) and SAF-T files with a combined extended SAF-T file upload called ‘JPK_VAT’ (i.e. JPK_7M’ for monthly filing frequency and JPK_V7K’ for the quarterly one). The new SAF-T file not only will combine the information that is currently reportable within the VAT returns and SAF-T files, but it will also include some additional pieces of information, which has never been required to date to be reported to the Polish tax authorities for VAT purposes, i.e. on the sales side it will be necessary to mark certain transactions with a specific code assigned to each category of products, services or types of documents. E.g. certain waste supplies will need to be marked with a code ‘05’, supplies of certain intangible services like consultancy, accountancy will need to be marked with a code ‘12’, distance sales made from Poland will need to be marked with a code ‘SW’, transactions subject to the split payment mechanism will need to be marked with a code ‘MPP’. Each error made on the new combined extended SAF-T file may be subject to a fine of PLN 500 (GBP 100; EUR 115; USD 125). The submission of the new combined SAF-T files from 1 April 2020 will be mandatory only for large companies (those with at least 250 employees or with an annual turnover exceeding EUR 50m). The remaining companies will be obliged to submit these new combined SAF-T files only starting from 1 July 2020.
  • New reduced VAT rates matrix – currently the goods and services falling under one of the two reduced VAT rates in Poland (5% and 8%) are identifiable by the Polish Classification of Goods and Services (PKWiU) whereas as of April 2020 the goods, to which a reduced VAT rate can apply will be listed using the Combined Nomenclature (CN) codes. Moreover, the scope of the application of the reduced VAT rates will slightly change, i.e. the aim of the Polish legislator was to simplify and make the application of reduced VAT rates more transparent and user-friendly by: i) covering as much as possible the entire product groups (CN divisions) with one rate; ii) general reduction of rates (‘downward equation’) if it was necessary to change the rate for given products. E.g. the VAT rate for tropical and citrus fruit will decrease from 8% to 5%, VAT rate for some spices like mustard or ground pepper will decrease from 23% to 8%, VAT rate for some hygiene products or products for babies and children like food, dummies, nappies, car seats will decrease from 8% to 5%. To balance out the effect of the reduced VAT rates simplification, on few selected goods the tax rate will increase (e.g. lobsters, octopus, crabs, shrimps as well as dishes which include these products will be subject to 23% standard VAT rate instead of the current 5/8% rate).
  • ‘Binding Rate Information’ (in PL ‘WIS’ – Wiążąca Informacja Stawkowa) –separately to the already existing institution of a ‘binding ruling’ (in PL ‘Indywidualna Interpretacja’) a new institution of a ‘binding rate information’ will be introduced. Currently, in order for a taxpayer to receive a binding ruling on the applicability of a reduced VAT rate to its products, the applicant of the ruling has to inform the tax authorities of the relevant Polish Classification of Goods and Services (PKWiU) code applicable to its products and the Polish tax authorities are not competent to interpret within the ruling whether or not the provided PKWiU code is correct (and the opinion issued by the Statistical Office was not binding as such). The new ‘Binding Rate Information’ will be an administrative decision, in which, on the basis of the taxpayer’s description of the supply/ingredients of the product etc., the tax authorities will confirm i) the CN (for goods), Polish Classification of the Building Objects (PKOB) or PKWiU (for services) code and ii) the relevant VAT rate applicable to the goods or services. Moreover, the ‘Binding Rate Information’ will be published by the National Tax Information in the Public Information Bulletin under the following link and it will be binding not only the person, to whom it was issued, but also other persons supplying identical goods or services:

https://www.kis.gov.pl/informacje-podatkowe-i-celne/wiazace-informacje-stawkowe-wyszukiwarka

  • Accounting for import VAT in VAT returns – taxpayers accounting for import VAT under the simplified provisions within the VAT returns will no longer be required to provide the tax authorities with the evidence of the import VAT having been accounted for in the VAT return.

 

Romania

With effect from 1 February 2020 the VAT split payment mechanism in Romania was abolished. It used to be applicable on a mandatory basis to insolvent or VAT indebted suppliers however, following the EU Commission’s warning that the measure was incompatible with the EU VAT Directive as it was disproportionate to the aims which it wanted to achieve, this mechanism was withdrawn by the Romanian government.

 

New Zealand

A wide ranging review of New Zealand GST is underway. The authorities have sought public comments on changes to the zero rating of land, the treatment of cryptocurrencies, the treatment of fund management services, new invoicing rules and treatment of second hand goods. The consultation document can be found here https://taxpolicy.ird.govt.nz/sites/default/files/2020-ip-gst-issues.pdf

Non-resident providers of B2C digital services: Obligation to VAT Register

Regular VATLife readers will know that in almost every edition we cover new countries adopting this rule for providers of internet based digital products. The latest countries to come on board with such an obligation for foreign suppliers of B2C e-services are as follows:

  • Mexico – 16% of VAT applicable on both B2C and B2B digital services as of 1 June 2020;
  • Canadian province of British Colombia– 7% of provincial sales tax (PST) will be applicable as of 1 July 2020;
  • Algeria – reduced VAT rate of 9% applicable as of 1 January 2020;
  • Cameroon – 19.35% of VAT should apply with effect from 1 January 2020;

The additional countries that are considering to impose VAT/GST on the B2C digital services provided by foreign suppliers are:

  • Fiji – 9% of VAT (planned effective date: unknown yet);
  • Ukraine – 20% of VAT (planned effective date: January 2021) subject to reaching the annual sales threshold of UAH 1m (circa USD$40,200, EUR€36,500, GBP£30,800);
  • Chile – 19% of VAT (planned effective date: unknown yet but should be late 2020).
  • Moldova – 20% of VAT (draft effective date: April 2020);
  • Kazakhstan – 12% of VAT (draft effective date January 2021).

Non-resident digital service providers: Obligation to VAT Register: New countries from January 2020

Forcing non-resident suppliers of digital services to register for VAT is a relatively easy way for tax authorities to generate windfall revenue. As a result, this provision, trailblazed by the EU, continues to spread across the world. Regular VATLife readers will know that we’ve covered many states as they have this measure. For January 2020, the new states are:

  • Uzbekistan – 15% VAT chargeable
  • Malaysia – 6% of digital service tax chargeable
  • Singapore – 7% GST chargeable, but subject to a limit of B2C digital sales into Singapore exceeding SGD 100k (EUR 66.5k; USD 74k; GBP 56,5k) and global sales exceeding SGD 1mln (EUR 665k; USD 740k; GBP 565k)

Paraguay and Ecuador are also introducing provisions to tax digital downloads locally, but they will do this via a withholding obligation on the payment provider. Suppliers will therefore need to factor this cost into gross sales figures.

UK: Digital ‘Newspaper’ Can Enjoy Zero Rating

The UK applies a VAT zero rating for books, newspapers and magazines. As these sectors have rapidly digitalised over the last years, the authorities have sought to strictly limit that privilege to the printed hard copy products originally envisaged when the law was drafted. A recent court case, however (News Corp UK & Ireland Ltd v HMRC Commissioners) has found in favour of the taxpayer that their digital ‘newspaper’ edition does, in fact qualify for zero rating. This could open up the prospect of significant VAT refund claims by similar providers. However, it is a ruling or relatively junior court (The Upper Tax Tribunal) and could be the subject of appeal. For the full ruling see here: http://financeandtax.decisions.tribunals.gov.uk/judgmentfiles/j10349/TC06385.pdf

The EU has introduced four measures as of 1 January 2020 to help standardise and (allegedly!) simplify cross-border transactions in the Single Market. They are commonly called Quick Fixes as they are intended to be interim measures before a long-planned review of the entire intra-EU trade regime later in the 2020’s.

Fix 1 – call-off stock simplification

Cross-border call-off stock (where a supplier sends goods to a customer’s location but sells them to the customer only as and when the customer needs them) has long been a difficult area. Under basic EU VAT law logic, the supplier would be required to treat the sales as local sales in the customer’s country and register for VAT there. However, to avoid unnecessary registrations, some Member States have long applied a simplification of treating these as intra-Eusales by the supplier and acquisitions by the customer. This simplication is now mandatory throughout the Union. It should be noted that this applies only to call-off stocks, where one customer is involved, not consignment stocks, where are shipped abroad and then allocated to multiple cusomers’ orders.

Fix 2 – chain transactions

Intra-EU chain transactions refer to successive supplies of the same goods with the goods being dispatched from the first supplier in the chain in one EU country directly to the last customer in the chain in another EU country. Therefore there are two or more consecutive supplies however there is just one intra-EU movement of those goods, leading to the question of which should enjoy the zero rating available for a trasaction involving an intra-EU movement. There has been a certain level of uncertainty in the legislation as to this matter, leading to frequent litigation and complex case law.

As of 1 January, it is now stipulated that the transport of goods should be ascribed to the first supply in the chain, that made to the intermediary operator, unless the intermediary operator is VAT registered in the country of dispatch of the goods and he communicates this number to the supplier, in which case the transport of goods should be allocated to the supply made by the intermediary operator (i.e. the first supply will be domestic one taxable in the country of dispatch and the second supply will be the exempt intra-Community one).

Fix 3 – mandatory VAT identification number of the customer for intra-Community supply

Currently in most EU countries it is already a requirement for the supplier to obtain and quote the customer’s valid EU VAT number on the invoice in order to exempt/zero-rate an intra-Community supply. However, even the European Court of Justice ruled it a merely ‘formal’ requirement, which has led to relaxed enforcement in some Member States.

As of 1 January 2020it will be a ‘substantive’ requirement in all Member States that a valid EU VAT number of a customer is obtained and quoted on the invoice. This means that, without it, the zero rating is legally lost and the supplier becomes liable to account for VAT on the supply. Furthermore, the transaction must also be reported on the recapitulative statement (European Sales List) in order to qualify for the exemption.

Fix 4 – proof of intra-Community transport

Currently there is no pan-EU criteria for the documentary evidence required to claim an exemption for intra-Community supplies. Each Member State can determine which documents are acceptable and sufficient as a proof of delivery of goods from one EU country to another. Consequently, the evidence is open to interpretation by different fiscal authorities (or even individual tax inspectors).

From 1 January 2020 there will be a ‘rebuttable presumption’ that the condition regarding the documentary evidence required to claim an exemption for intra-Community supplies of goods has been fulfilled if:

 

  • The supplier is responsible for the and holds two non-contradictory pieces of evidence, such as:
    • – Customer-managed relationship documents, bills of lading, or airfreight or carrier invoices;

Or:

  • One piece of evidence such as that above, plus:
    • – An insurance policy in relation to the transport of the goods; Or
    • – Banking documents in relation to the movement of goods
    • – Official documents issued by a public authority confirming arrival of goods in the Member State of destination, or
    • – A receipt from a warehouse

Or:

  • the customer is responsible for the shipment of the goods and the supplier holds:
    • – Two non-contradictory pieces of evidence as above (but not the alternatives, only the non-contradictory pieces of evidence) and:
    • – A written statement from the customer that it has acquired the goods into another Member State keeper for storage of goods in the Member State of destination.

As can be seen from the complexity of the list, this ‘simplification’ may be a double-edged sword. While bringing taxpayers certainty in some Member States where inspectors have been making excessive or even vexatious demands for documentation, it is likely to raise the bar for compliance in those Member States that have had a more relaxed enforcement of this matter.

If you would like to read more on the Quick Fixes, you can access a detailed EU summary here: https://ec.europa.eu/taxation_customs/sites/taxation/files/explanatory_notes_2020_quick_fixes_en.pdf

There are always VAT rate changes at New Year. 2020 is not a ‘bumper’ year for these, but there are a few:

Croatia

A reduced 13% VAT rate is to apply in Croatia in the hospitality sector (i.e. preparating and serving of meals, including desserts, in and outside a catering facilities) from 1 January 2020.

Hungary

With effect from 1 January 2020 Hungary will reduce its VAT rate for accommodation services from 18% to 5%.

Slovenia

As of 1 January 2020 a new reduced VAT rate of 5% will be introduced in Slovenia and it will apply to publications (both printed and e-books).

UK

Brexit

Brexit is now set to go ahead on 31 January, with the terms of the Withdrawal Agreement of 17 October 2019 applying (although, as at publication, the European Parliament has not yet formally ratified this). The agreement stipulates a transition period up to 31 December 2020, during which the UK will remain in the EU VAT zone and VAT impacts for business should be minimal. The post-transition regime is yet to be laid out in detail. For a full copy of the agreement see here: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/840655/Agreement_on_the_withdrawal_of_the_United_Kingdom_of_Great_Britain_and_Northern_Ireland_from_the_European_Union_and_the_European_Atomic_Energy_Community.pdf

Poland

Split payment mechanism on certain supplies in place from November 2019

As of November 2019 taxpayers in Poland are obliged to apply a split payment mechanism when making the bank transfer payments to their suppliers in respect of supplies above PLN 15k (GBP 3,5k; EUR 4k; USD 4.5k) in value, or all supplies in certain high risk sectors.

For supplies falling under the mandatory split payment mechanism, the supplier should have included a statement ‘Split payment mechanism’ on the invoice.

Under the split payment mechanism the purchaser splits the payment when making the bank transfer to the supplier, with the net amount being paid to the supplier’s regular account and the VAT amount being paid to a special ‘VAT account’ of the supplier held by his bank.

Funds held by a taxpayer in its ‘VAT account’ can be used to make the payments of VAT, corporate income tax, excise, customs and social security liabilities. A taxpayer can also apply to the Polish tax authorities for the funds gathered on the ‘VAT account’ to be transferred to its regular bank account.

You can read more about the system (in Polish) on the Polish government website here https://www.gov.pl/web/rozwoj/bezpieczna-transakcja-mechanizm-podzielonej-platnosci-split-payment-w-praktyce

New obligation from January 2020 to verify suppliers in ‘White List’ of taxpayers

Starting from 1 January 2020, businesses registered for VAT in Poland making bank transfers to their suppliers in respect of invoices documenting transactions of supplies exceeding PLN 15k (GBP 3,5k; EUR 4k; USD 4.5k) should verify whether the bank account of the supplier is listed in the so-called ‘White List’ of verified taxpayers.

The ‘White List’ is an online database run by the Polish tax authorities allowing companies to verify the VAT status (e.g. VAT registered vs. unregistered), as well as certain other information, about their business counterparties.

Penalties for paying to a non-White list account can be avoided if, within 3 days from ordering such a payment, he notifies the local tax office of the supplier of the bank account details, to which the payment was made. Alternatively, a company can pay the invoice using the split payment mechanism to avoid the joint and several liability for VAT purposes.

According to the recently published by the Polish Ministry of Finance ‘Explanatory Notes’ of 20 December 2019 concerning these new obligations, the foreign bank accounts will not be displayed within the ‘White List’ database.

You can access the White List search page here https://www.podatki.gov.pl/wykaz-podatnikow-vat-wyszukiwarka