Fiscal subject related
The cash deposit system is a way to collect used beverage packaging from the market. Features of that system are:
- An additional fee (deposit) will be added to selected beverages at the checkout.
- The deposit will be refunded to the consumer when they return the used (empty) packaging to the store.
- The amount of the deposit paid by the consumer will be specified on each package.
- Producers of beverages in glass packaging will be obligated to charge VAT at the end of the calendar year on packaging of this type issued to buyers but not returned.
- Consumers will be able to return used packaging throughout the country without showing a purchase receipt.
For the taxpayers and sellers, that means that they will have to create and finance the activities of the deposit refund system operator or operators. The operator will operate as a joint-stock company. To operate the system, they will need a special permit from the Minister of Climate. Also, they will need to prepare for different settlement rules for reusable and single-use bottles, decide whether to maintain the previously used cash deposit system, and prepare for the need to annually adjust the VAT settlement due to the balance of bottles issued and returned by the operator in a calendar year. Furthermore, those introducing drinks in packaging to the market will also need to maintain a new type of record-keeping for VAT purposes.
It’s also important to note that for certain types of packaging, previous return packaging rules will be retained, meaning different documentation and records will be required depending on the nature of the taxation. This creates a whole set of issues related to the accounting and taxation of financial flows between the store, consumer, and operator, with the store being a central element. Documentation, record-keeping, and tax settlement of these flows are new areas where thorough and early preparation will be vital to ensuring the tax security of retailers.
Agreements with operators will cover both those introducing packaged drinks to the market (an agreement on joining the cash deposit system) and retail points of sale (agreements concerning deposit collection and packaging retrieval).
Then, according to current information, only retail spaces exceeding 200 m2 will be required to participate in the system, but this can be used for smaller retailers.
From a fiscalization perspective, it is mostly about the data that will be presented on the receipt. Once the rules are implemented, we will see what will be changed and how the system will be recorded.
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