Odliczanie VAT z faktury wystawionej przez niezarejestrowanego podatnika

Organy podatkowe w Polsce stoją na stanowisku, że podatnik VAT nie ma prawa odliczyć VAT naliczonego z faktury wystawionej przez podmiot niebędący zarejestrowanym czynnym podatnikiem VAT. Uznają bowiem, że jest to faktura wystawiona przez podmiot nieistniejący.

Jeszcze bardziej sprawę komplikuje fakt, że obecnie rejestracja nowego podatnika VAT trwa nawet kilka miesięcy. Nowy podatnika rejestruje działalność w CEiDG, zgłasza się na VAT i czeka na nadanie mu statusu czynnego podatnika. (Statut czynnego podatnika można sprawdzić w wyszukiwarce na stronie Ministerstwa Finansów.) Jednocześnie kończy się miesiąc i trzeba wystawić fakturę za wykonane prace, wyświadczone usługi. Organy podatkowe nie mają wątpliwości, że faktura musi być wystawiona, a VAT odprowadzony do urzędu skarbowego w terminie.

Co ma zrobić podmiot otrzymujący fakturę? Pomocne w tym zakresie może być kolejne pozytywne orzeczenie Trybunału Sprawiedliwości Unii Europejskiej. 19 października 2017 roku zapadł wyrok w sprawie rumuńskiego przedsiębiorcy w sporze z organem podatkowym. Trybunał uznał, że regulacje prawa krajowego, na podstawie których podatnikowi odmawia się prawa do odliczenia podatku od wartości dodanej z tego względu, że podmiot, który świadczył na jego rzecz usługę i wystawił z tego tytułu fakturę, na której wyraźnie zostały wskazane wydatki i podatek od wartości dodanej, został uznany przez organ podatkowy państwa członkowskiego za nieaktywny jako niezgodne z Dyrektywą. Należy tu zaznaczyć, że uznanie podatnika za nieaktywnego zostało opublikowane i jest dostępne na stronie internetowej dla wszystkich podatników w tym państwie.

Trybunał podkreślił, że jeżeli nie zachodzą przesłanki do stwierdzenia przestępstwa podatkowego, usługa została faktycznie wykonana i prawidłowo udokumentowana, to pozbawienie nabywcy prawa do odliczenia VAT naliczonego jest naruszeniem zasady neutralności podatku VAT.

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