We can be sure that the word “KSEF” is and will be mentioned for a long time in all cases. But this is not surprising, because from 1 February next year it will be the cause of one of the biggest revolutions in Polish tax law. There are still a lot of doubts, confusions, ambiguities. One of them is when a VAT taxpayer uses the services of a foreign accounting office or, as is the case in larger groups of entities – a foreign clearing centre (foreign company). How to grant such an entity the right to use the KSEF in a situation where it does not have a Polish tax identification number (NIP) and its employees/representatives have PESEL numbers?
To answer the above question, the key is of course the conditions and systemic possibilities. This is particularly important for foreign groups of entities, where this accounting is often centralized and carried out on global ERP systems, for which Polish tax regulations are not the most important point of reference.
Nevertheless, one of the most common solutions for cooperation in the model with a foreign accounting office/clearing center is a situation where, with the applicable global software, a certificate generated on an electronic seal (or token) at the “master” level will be uploaded. And then, individual accesses to data, limited permissions, will take place at the local level. This will also include the assigned rights for a foreign accounting office/clearing center.
If there is no such possibility, the alternative is to solve the actual granting of rights to a foreign entity or a natural person from this entity. However, the above is associated with the need for this entity/person to authenticate themselves through a qualified seal/electronic signature (SHA256), under which the identity is confirmed by a fingerprint (PESEL or NIP not required).
In this situation, currently in the MCU module, and soon directly through integration with the KSEF database, when granting permissions for such an entity/person in the “Type of authorized entity” field, we select: “A natural person using a certificate without a NIP or PESEL identifier” (if we are entitlement to a natural person). Then, after selecting this option, you will need to enter a “certificate fingerprint”, within which this field contains the following description: “A field that allows you to enter the fingerprint of the certificate, which consists of 64 characters between 0 and 9 and A to F”.
As indicated in the KSEF manual, the use of this type of authentication “will most often apply to foreign taxpayers who have a qualified signature or a qualified seal issued in another country (without NIP and PESEL).”
After transferring authorizations, this person, through their software (ERP system), which should be integrated with KSEF, will be able to perform activities in KSEF for which they have been authorized.
Theoretically, there would also be a technical possibility of transferring a generated token or a downloaded certificate containing specific permissions to a foreign accounting office/clearing house. However, we do not recommend this (especially with regard to certificates that technically confirm identity, such as an electronic signature or seal). Nevertheless, we are aware that in the end everything will depend on the adopted model of functioning with the KSEF, the approved procedures, which are particularly important, in reality the Polish company operates in a foreign group of entities.
