Odroczenie prawa do odliczenia VAT naliczonego przy odwrotnym obciążeniu niezgodne z dyrektywą VAT?

Od 1 stycznia 2017 roku do ustawy o VAT ustawodawca wprowadził zasadę, że w przypadku rozliczenia wewnątrzwspólnotowego nabycia towarów, importu usług oraz odwrotnego obciążenia w obrocie krajowym VAT należ = VAT naliczony tylko wówczas, gdy rozliczenie transakcji nastąpi najpóźniej do końca trzeciego miesiąca licząc od daty powstania obowiązku podatkowego (art. 86 ust 10i ustawy o VAT).

Przykładowo: jeśli zagraniczny wykonawca wykonał na rzecz polskiego podatnika usługę we wrześniu – obowiązek podatkowy dla importu usług powstał we wrześniu. Jeśli podatnik nie rozliczył tej transakcji w tym miesiącu, bo np. nie posiadał faktury wystawionej przez świadczeniodawcę, to jest zobowiązany złożyć korektę deklaracji za wrzesień. Jeśli korekta zostanie złożona do końca grudnia – w skorygowanej deklaracji wykazuje VAT należny i VAT naliczony. Jeśli korektę złoży w późniejszym terminie – w korygowanej deklaracji za wrzesień wykaże VAT należny, natomiast VAT naliczony ma prawo doliczyć w deklaracji za okres bieżący. Powoduje to powstanie zaległości podatkowej i konieczność zapłaty odsetek.

29 września 2017 roku zapadł pierwszy wyrok Wojewódzkiego Sądu Administracyjnego w zakresie ocen zgodności powyższych przepisów z Dyrektywą o VAT. WSA w Krakowie (sygn.: I SA/Kr 709/17) uznał, że polskie przepisy naruszają podstawową zasadę podatku VAT tj. zasadę neutralności. W uzasadnieniu wyroku czytamy: „Przepisy ustawy o VAT w brzmieniu obowiązującym od 1 stycznia 2017r. wprowadzają bowiem automatyczne przesunięcie w czasie prawa do odliczenia i związaną z tym konieczność zapłaty odsetek za zwłokę z przyczyn czysto formalnych, bez względu na brak wystąpienia w danej transakcji jakiegokolwiek ryzyka oszustwa podatkowego lub świadomego nadużycia prawa. Odsetki bowiem także muszą być objęte zakresem neutralności skoro obowiązek ich uiszczenia powoduje obciążenie finansowe dla podatnika, wynikające z rozliczenia podatku w warunkach określonych w art. 86 ust 10b i 10i Jest to skutek nie do pogodzenia z zasadą neutralności ale także z zasadą proporcjonalności. Przepisy VAT powinny być interpretowane w taki sposób, aby podatek nie był obciążeniem dla przedsiębiorców, zarówno w aspekcie odliczenia, jak i odsetek związanych z ewentualną zaległością wynikającą z niedochowania wymogów formalnych odliczenia„.

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