As the global e-invoicing landscape continues to shift and develop, our quarterly VAT Snapshot webinar brings you all the details on the key regulatory changes to watch.

Join Dilara Inal and Marta Sowinska from our Regulatory Analysis and Design team for a 30-minute update on the latest developments in e-invoicing regulations across Europe and beyond.

This session will cover:

Ever-changing Insurance Premium Tax (IPT) rules and regulations can be challenging to keep up with, so staying on top of the latest developments in IPT compliance is key.

Join our insightful webinar where Sovos’ IPT experts Edit Buliczka, James Brown and Jake Thorne will deep dive into the intricacies of remaining compliant in Hungary and discussing the current and the potential future impacts of the climate change to the IPT regulations across Europe and beyond.

Remaining current with the latest regulatory revisions in VAT reporting and SAF-T requirements in Poland. This webinar will deliver a comprehensive overview of recent changes to ensure you thoroughly understand the evolving compliance landscape. Gain valuable insights into essential strategies and best practices for preparing for VAT audits, mitigating risks and avoiding penalties.

The EU Directive for VAT has laid the groundwork for a harmonised VAT system throughout the different Member States. However, the implementation of the EU VAT law within the national jurisdictions still creates a disparity between its application and conditions to be met, specifically regarding some of the intra-EU simplifications to be applicable.

Following a webinar covering regulatory updates alongside key points of the VAT recovery process, this blog aims to shed light on the crucial aspects of VAT recovery – especially fast-approaching deadlines.

Understanding the nuances of VAT recovery applications is essential for businesses seeking to optimise operational costs by recovering VAT incurred in a different country. Let’s explore the fundamental aspects of the VAT recovery process.

The VAT recovery process

Businesses can reclaim VAT incurred during their operations through VAT returns if registered in the country where costs are incurred. However, for those not registered and with no obligation to do as such, alternative routes such as the EU Refund Claim or 13th Directive procedure are available – provided specific criteria are met.

Before initiating a VAT refund claim, companies must carefully evaluate their taxable activities. Failure to identify taxable activity in the relevant country may result in the rejection of the VAT recovery application. In such cases, registering for VAT becomes imperative to facilitate input VAT recovery through VAT returns, subject to each country’s rules regarding retrospective VAT registration.

Recoverable expenses

The range of recoverable expenses varies across countries, encompassing equipment, tooling, event costs, professional fees, accommodation and so on. However, due to varying regulations, conducting a comprehensive recoverability assessment based on each country’s VAT legislation is crucial before applying.

Meeting deadlines

Adhering to deadlines is critical for successful VAT recovery.

EU businesses seeking VAT refunds from other Member States must submit an EU Refund Directive application by 30 September of the subsequent calendar year. Non-EU businesses aiming to reclaim VAT incurred in EU Member States should file a 13th Directive application by 30 June of the following year.

While some countries share a common deadline of 30 September, missing deadlines may restrict refund requests. Notably, even though in most cases, these deadlines cannot be extended, there are countries like the Netherlands where refund requests can be submitted to tax authorities up to five years back rather than just for the previous fiscal year.

Understanding reciprocity

Reciprocity agreements are pivotal in VAT refund claims, with most EU Member States mandating reciprocity. Understanding these laws is essential to avoid failed attempts at reclaiming VAT in non-reciprocal jurisdictions.

Recent updates include the UK-Italy agreement under the 13th VAT Directive, streamlining VAT refund claims for UK businesses. Notably, the deadline for a 13th directive application in Italy is September 30th, 2024, for all costs incurred during 2023 (i.e., purchase invoices dated in 2023). This represents a significant advancement toward streamlined cross-border VAT recovery processes for UK businesses. Additionally, it may be advantageous for businesses to revisit already submitted 13th Directive claims in Italy that were previously on hold due to the lack of reciprocity.

In conclusion, mastering the intricacies of VAT recovery empowers businesses to enhance financial efficiency and mitigate costs effectively. By navigating the essentials outlined above, businesses can embark on a journey toward unlocking their full VAT recovery potential.

Take Action

Want to learn more about the VAT recovery process? Our expert team can help.

In Austria, the insurance premium tax law regulates the indirect tax that applies to elements of coverage under a motor insurance policy. This blog details everything you need to know about this particular indirect tax in the country.

As with our dedicated overviews of the taxation of motor insurance policies in Spain and Norway, this blog will focus on the specifics in Austria. We also have a blog covering the taxation of motor insurance policies across Europe.

Which taxes are payable concerning motor insurance policies in Austria?

In Austria, Vehicle Insurance Tax (VIT), or the so-called motor-related insurance tax, is payable in relation to:

VIT is payable in addition to the 11% insurance premium tax (IPT).

How is VIT calculated for motor insurance policies in Austria?

The calculation of VIT is complex. The tax is determined by the type of vehicle, the engine capacity/displacement and CO2 emissions for motorbikes, the performance of the combustion engine and the emission in grams per kilometer for passenger automobiles and the power of the combustion engine for all other engine types.

The date of registration is another item to consider when calculating the amount of VIT. The computation for automobiles registered before 1 October 2020 is different, however.

The following rates are effective for passenger cars registered after 1 October 2020 are as follows:

In 2020, the first component, power, was lowered by 65 Kwatt, while the second component, emission, was reduced by 115 grams per kilometre. Since 2021, the deduction has been lowered annually. Every year, the first component is reduced by one and the second by three. As a result, in 2024, the deductions are 61 Kwatt and 103 grams per kilometre.

To complicate this further, the aforementioned calculation only applies to M1 passenger cars whose CO2 emissions were established using the WLTP (Worldwide Harmonised Light Vehicle) test method. If this process is not followed, the calculation will be different.

Special rates apply to motorhomes, motorcyclists and other multi-track motor vehicles.

The computed amount is due monthly. Prior to 2020, the regularity of the payment was another aspect to consider in the computation.

What vehicles are exempt from tax in Austria?

First and foremost, VIT is required on motor vehicles weighing up to 3.5 tonnes. If the vehicle’s weight exceeds this limit, another type of tax – motor vehicle tax – is due.

The exemptions in Austria follow the usual considerations mentioned in our blog on taxation of motor insurance policies across Europe. Exemptions are dependent on:

Read our IPT Guide to learn more about Insurance Premium Tax compliance.

Take Action

If you still have questions about the taxation of motor insurance policies or IPT in Austria, speak to our experts.

Unlock the secrets to fruitful global trade in our latest webinar; our consulting expert Luca Clivati will provide valuable insights and guidance to help businesses maximise operational and financial efficiency when trading globally.

Keeping up with e-invoicing requirements has never been a bigger task, especially if you operate internationally. Join us as we share the latest information necessary to successfully navigate the latest updates to the global e-invoicing landscape. This webinar will cover:

• Expansion of Romania’s e-transport mandate since December 2023
• Development of Spain’s SIF/Verifactu requirement
• Postponements in Portugal
• The legislative process for B2B Public Administration mandatory e-invoicing in Germany and Belgium
• Important dates to be aware of in Poland
• Recent changes to Malaysia’s e-invoicing mandate
• Date changes and key features in Israel

Stay updated on VAT Reporting and SAF-T with Sovos’ webinar. Explore legislative changes, prepare for VAT Recovery deadlines, and gain insights into SAF-T updates for Portugal, Bulgaria and Poland. Understand recovery claims essentials, crucial with the nearing 13th Directive deadline.

e-invoicing in Poland: B2B, B2G, KSeF

Poland’s e-invoicing requirements are in flux. While B2G transactions have required electronic invoices since April 2019, the country’s B2B e-invoicing rules are set to come into effect in February 2026 for taxpayers whose turnover exceeds PLN 200 million (approx. EUR 46 million) in the preceding year, and in April 2026 for all other taxpayers.

Staying in the know is vital if your business is to avoid costly penalties.

Continue reading to learn about the current status quo of Poland e-invoicing, including the introduction of a Continuous Transaction Controls (CTC) system via the KSeF platform, as well as what you can expect going forward.

At a glance: Poland e-invoicing

Poland B2G e-invoicing

CTC Type
E-Invoice clearance via KSeF or PEF for B2G transactions carried out with public institutions will take effect in February 2026 for taxpayers whose turnover exceeds PLN 200 million (approx. EUR 46 million) in the preceding year and in April 2026 for everybody else.

Network
Possible e-invoice issuance both via PEF and KSeF. If B2G, e-invoice will be issued in PEF and automatically transferred to the KSeF in order to assign a KSeF number. The PEF invoice will be visible in the KSeF in the appropriate tab for PEF invoices, and the information about the assigned KSeF number will be available in PEF.

Format
PEF format or KSeF format supporting XML invoices following the logical structure FA_VAT.

eSignature Requirement
A qualified electronic signature is one of the means that taxpayers must use to authenticate in KSeF.

The integrity and authenticity of an invoice are ensured by issuing structured e-invoices via KSeF.

Archiving Requirement
10 years.

Poland B2B e-invoicing

CTC Type
E-invoice clearance via KSeF for transactions carried out by registered VAT-taxable taxpayers will take effect in February 2026 for taxpayers whose turnover exceeds PLN 200 million (approx. EUR 46 million) in the preceding year and in April 2026 for everybody else.

Network
Centralised network where the e-invoice exchange is processed through the KSeF platform provided by the Ministry of Finance.

Format
XML following the logical structure FA_VAT.

eSignature Requirement
Qualified electronic signature is one of the means that taxpayers must use to authenticate in KSeF.

The integrity and authenticity of an invoice are ensured by issuing structured e-invoices via KSeF.

Archiving Requirement
10 years.

E-invoicing regulations in Poland

Tax compliance is monitored and regulated by the Ministry of Finance, particularly the National Revenue Administration. After implementing the SAF-T changes in Poland in the form of JPKs, the Ministry of Finance is currently revolutionising the invoicing system, introducing the centralised platform Krajowy System E-Faktur (KSeF) for the transmission of structured e-invoices.

Since 2019, public entities in Poland have been mandated to receive and process e-invoices. While currently optional for suppliers of public entities, the transmission of e-invoices will be required for B2G and B2B transactions when the mandate is implemented in 2026.

KSeF Poland: National Electronic Invoicing System

Poland has introduced a national electronic invoicing system called KSeF (Krajowy System e-Faktur), which is a centralised platform for issuing and exchanging electronic invoices with a structured format – currently logical structure FA (2). The go-live date for issuing and receiving invoices via KSeF has been postponed three times since it was originally announced. Once in action, buyers and suppliers in B2B and B2G transactions will be mandated to issue and receive e-invoices through the KSeF platform.

Poland B2B e-invoicing

The issuance of electronic invoices through KSeF has been voluntary for businesses since 1 January 2022, meaning suppliers can issue e-invoices via KSeF. However, buyers can still request to receive them in a different format outside of KSeF.

This will change when e-invoicing via KSeF becomes mandatory in 2026 for the majority of businesses in Poland – namely registered VAT taxpayers who have fixed establishments on the territory of Poland, and in the later stages to VAT-exempt taxpayers.

Poland B2G e-invoicing

Poland’s own portal, PEF (Platforma Elektronicznego Fakturowania), has been in place since 2019. It aims to centralise and facilitate B2G e-invoice transmission allowing private companies and public bodies to issue and receive electronic invoices. All public entities in Poland have been obliged to register on PEF and receive structured e-invoices since 18 April 2019.

When the mandate takes effect, the PEF and KSeF systems will merge, meaning that e-invoicing in B2G transactions will be possible both via PEF and KSeF. B2G invoices will also need to receive a unique KSeF ID.

For instance, taxpayers will be able to use features available in KSeF like semantic validation of the e-invoice. Tax authorities will be able to access such invoices, regardless of if they were issued through PEF or KSeF. Therefore, it will be possible to continue issuing B2G invoices via PEF and according to the PEF e-invoice standard.

Timeline: e-invoicing adoption in Poland

The implementation of e-invoicing in Poland has been done in stages. Here is a brief timeline of electronic invoicing’s adoption in the country:

  • October 2021: Testing period of KSeF begins
  • December 2021: Testing period of KSeF ends
  • 1 January 2022: Voluntary use of KSeF commenced
  • 17 June 2022: Poland received the derogatory decision from the VAT Directive to introduce mandatory e-invoicing via KSeF
  • 1 December 2022: Ministry of Finance published draft legislation amending the VAT Act regarding mandatory e-invoicing’s implementation
  • 15 March 2023: Poland publishes second draft law amending the VAT Act, including KSeF changes
  • 16 June 2023: the law amending VAT Act is published by the Ministry of Finance
  • 1 February 2026: KSeF enters into force for the taxpayers whose turnover exceeds PLN 200 million (approx. EUR 46 million) in the preceding year
  • 1 April 2026: KSeF enters into force for all taxpayers

After the mandatory e-invoicing goes live, the administrative penalties for non-compliance will apply and it will no longer be possible to issue invoices using cash registers.

Refer to this blog for an in-depth timeline about e-invoicing in Poland.

Benefits of e-invoicing

While businesses will be legally required to use electronic invoices, there are benefits that taxpayers can enjoy when comparing e-invoices to traditional, paper invoicing. These include:

  • Cost savings: Reducing paper usage, postage and manual labour
  • Time savings: Electronic invoices use standardised formats and automated processes
  • Convenience:  e-invoices increase interoperability across businesses
  • Increased security: Authentication and validation ensure the authenticity of transactions and the according invoices

Learn more about Sovos’ e-invoicing solution.

How to choose the right e-invoicing software in Poland

It’s not enough to accept software that accommodates e-invoicing without adapting it to the often-changing local rules and standards, resulting in the new status quo right as it comes into effect.

While functionality is important, also consider the future when choosing your ideal e-invoicing software provider.

International businesses must keep their eye on the bigger compliance picture, looking beyond local mandates to ensure they are meeting their obligations everywhere they do business. This can be heavy on resources, especially when considering the scope for regulatory updates across multiple jurisdictions.

This is why it is key to work with a global provider such as Sovos.

Future of e-invoicing in Poland

The future of e-invoicing is clear: Poland is working towards a vast implementation. A mandate will enter into force in February 2026, and become a requirement for many taxpayers. However, the impending implementation of VAT in the Digital Age cannot be forgotten when considering the future of e-invoicing in Poland. Designed to digitise the VAT system in the EU, the proposal may deliver further changes to how established taxpayers in the country do business.

The future of e-invoicing and tax as a whole may be uncertain across the European Union, but Sovos can provide your organisation with the consistency and peace of mind you require. Bookmark this page to remain updated with the latest developments that may affect how you do business.

Additional obligations for VAT compliance in Poland

Keeping on top of the upcoming e-invoicing requirements is important, but it’s also crucial to remember other obligations your business may face when complying with Poland’s VAT regulations.

While adapting to the pressure of implementing e-invoicing, taxpayers need to remain mindful of overall VAT Compliance and the current SAF-T mandate in Poland.

The results of non-compliance can change businesses forever, but Sovos is here to help you stay on top of your obligations.

Setting up e-invoicing in Poland with Sovos

Sovos prides itself in its continuous transaction controls (CTC) software which is purpose-built for customers who must remain on top of tax obligations wherever they do business – even as regulations change in the future.

Taxpayers established in Poland will be starkly aware of the evolving demands of compliance, with B2B and B2G transactions eventually requiring electronic invoices.

As CTCs and e-invoicing rise in prominence globally, there has never been a better time than now to find a compliance partner who understands the rules in play and is already looking ahead at what’s to come. Sovos is the provider you can trust.

The Sovos e-invoicing compliance solution was put to work by Brown-Forman, which looked to ease the burden of compliance from its IT department. Brown-Forman was able to reallocate its resources to core business functions with peace of mind, knowing that Sovos was there to ensure its e-invoicing requirements were being met.

Get in touch with us

FAQ

E-invoicing is mandatory in Poland for B2G transactions, when supplying goods or services to public sector entities that have an obligation to receive e-invoices. This will change, when B2B e-invoicing becomes obligatory via KSeF from February 2026.

Taxpayers will be mandated to electronically report specific information through KSeF, e.g. in cross-border transactions. In practice, e-invoicing and e-reporting are performed in the same way. The final date of introducing mandatory e-invoicing in Poland is still to be announced, after Ministry of Finance conducts the technical audit of the KSeF system.

Sovos has the first global solution for e-invoicing compliance, including e-reporting functionality.

Poland’s VAT Act mandates that invoices must be issued in two copies, with one being sent to the customer. Invoices cannot be raised before 30 days of the date of the delivery of the goods or services, but also no later than 15 days after the month they were delivered.

VAT invoices must contain numerous details as required by the tax authority, including the likes of:

  • Date of issuance
  • A unique identification number
  • Full name and address of buyer and seller
  • Description of type and quantity of supplied goods, or type and extent of rendered services
  • Date of transaction
  • VAT rate and amount payable

With the implementation of mandatory e-invoicing, additional data points are required to comply with the invoice schema.

Sending and receiving electronic invoicing for B2B and B2G transactions via KSeF in Poland will become mandatory from February 2026 for taxpayers whose turnover exceeds PLN 200 million (approx. EUR 46 million) in the preceding year – and in April 2026 for all taxpayers.

KSeF (Krajowy System e-Faktur) is Poland’s national electronic invoicing system, which is a centralised platform for issuing and exchanging electronic invoices. E-invoices must follow a structured format, currently logical structure FA (2).

QR codes will be mandatory on the graphical representation of the invoices shared outside of KSeF with the counterparties, invoices issued in the offline modes and VAT RR and VAT KOR RR invoices.

Currently, e-invoicing via KSeF and SAF-T will work parallel with each other in Poland.

VAT Compliance in Poland: An Overview for Businesses

Poland VAT compliance can be a tall task for those yet to devise a future-proof strategy. Considering legislation changes frequently and the ongoing phased implementation of e-invoicing, it takes a lot of time, money and energy to meet your obligations.

This is your overview of all the tax compliance rules applicable in Poland, covering mandates and requirements such as VAT, SAF-T (JPK) and e-invoicing via KSeF. Add this page to your compliance toolbelt so you can understand and meet your obligations – both now and in the future.

VAT obligations in Poland

There are several tax obligations in Poland that taxpayers must be mindful of. These include:

Poland: Insurance Ombudsman Contribution

While Poland does not have an Insurance Premium Tax (IPT) regime, it does have some parafiscal charges that are applicable to the insurance premium.

The Fire Brigade Tax (FBC) is applicable in special cases. There is also a so-called Financial Ombudsman Charge (FOC) to be settled online and paid to the Polish Financial Ombudsman Office on a yearly basis. This charge is applicable for all insurance companies operating under Freedom of Services (FOS) or Freedom of Establishment (FoE) in Poland as well as for Domestic Insurance Companies.

Previously, Insurer Ombudsman Charge (IOC) applied to all 18 classes of non-life insurance and life insurance policies. It was replaced by the Financial Ombudsman Charge (FOC) in January 2023.

Import VAT in Poland

The act of importation is a taxable event for which VAT is chargeable in Poland.

There is an option to use postponed accounting on imports. Poland introduced the option to defer import VAT as of 1 July 2020, enabling businesses to declare the tax through the VAT return without any cash payment. This mechanism is a great cash flow for the company as it doesn’t have to advance the VAT at Customs.

Taxable persons can use the mechanism, irrespective of whether the goods are subject to simplifications from the EU Customs Codes. To use the deferment mechanism, taxpayers must have a clear history of recent VAT compliance.

Invoicing requirements in Poland

Polish VAT invoices must be issued no later than the 15th day of the month after the taxable supply, and no earlier than 30 days before the supply of goods or completion of a service.

The electronic invoice will be considered issued on the day it is sent to KSeF, i.e. at the moment when it enters the system. When a structured invoice is assigned a KSeF number (unique ID), which contains the date of issue, it becomes legally valid. The issuance date is also in the Official Receipt Certificate (UPO).

To learn more about e-invoicing requirements in Poland, read our dedicated Poland e-invoicing overview.

Registration for OSS in Poland

One Stop Shop (OSS) has been effective in Poland since 1 July 2021, aiming to simplify VAT obligations for companies involved in distance selling.

Its main benefit is that a supplier can choose to account for the VAT due under OSS, which can be used for intra-EU cross-border supplies of goods and all cross-border supplies of services made to final consumers in the EU.

As a result, the company is required to register for VAT in only one EU Member State instead of registering for VAT in all EU Member States in which it operates – provided that the pan-EU threshold of EUR 10,000 in intra-EU distance sales to consumers is exceeded.

OSS can be used by businesses established in and outside the EU. If a supplier or a deemed supplier decides to register for OSS, it must declare and pay VAT for all supplies (goods as well as services) that fall under OSS.

Where the Member State of identification is Poland, the taxable person is entitled to file a notification to II Urzad Skarbowy Warszawa Srodmiescie by electronic means.

The forms for the EU OSS procedure are as follows:

  • VIU-R – notification form
  • VIU-DO – Form of the return for VAT settlements, filed for each quarter by the end of the month following a given quarter

The forms for non-EU OSS procedure are as follows:

  • VIN-R – Notification form
  • VIN-DO – Form of the return for VAT settlements, filed for each quarter by the end of the month following a given quarter

If you need help, please contact us or find more information on our dedicated guide.

Registration for IOSS in Poland

Import One Stop Shop (“IOSS”) is effective as of 1 July 2021 and applies to B2C distance sales of goods from outside the EU.

Under the standard procedure, VAT is due on all commercial goods imported into the EU Member State (the country of destination).

The purpose of IOSS is to facilitate the declaration and payment of VAT due on the sale of low-value goods of consignment valued at less than EUR 150. If the IOSS is used, the importation into the EU is exempt from VAT.

When using IOSS in Poland, a taxable person without a registered seat in the territory of the EU must indicate Poland as the Member State of identification. The taxable person in charge of the supply, or the intermediary, is entitled to file a notification with the II Urzad Skarbowy Warszawa Srodmiescie electronically.

The forms for the IOSS procedure are as follows:

  • VII-R – Notification form of taxable person
  • VII-RP – Notification form of intermediary
  • VII-DO – Form of the return for VAT settlements, filed for each month by the end of the month following a given month

If you need help, please contact us or find more information on our IOSS overview.

Intrastat and EC Sales list in Poland

Intrastat is an obligation for certain businesses that trade internationally in the European Union, relating to the movement of goods across EU Member States.

While the requirements remain similar across the region, certain Member States have implemented rules differently and each has its own Intrastat threshold for reporting. Poland’s declaration threshold for 2024 is PLN 6.2 million for arrivals and PLN 2.8 million for dispatches.

Find out more with our Intrastat guide.

VAT compliance in Poland FAQ

The standard procedure for VAT returns in Poland includes monthly filing. Taxpayers deemed as ‘small’, however, can file VAT returns quarterly if they meet specific requirements. VAT returns can be submitted by the official portal or through approved software.

VAT returns need to be filed by the 25th of the month following the accounting period. This is of utmost importance as taxpayers can be financially penalised for failing to meet the deadline, as well as the potential to accrue statutory interest and potentially face legal proceedings.

Since October 2020, there has been a Uniform Control File (JPK_VAT) that is made up of a record section and a declaration section. This consolidates data that was included in VAT returns prior to the file’s introduction.

There is a host of required information that must be included on invoices, including (but not limited to):

  • Date of issuance
  • Customer’s VAT ID number
  • Full name and address of both the supplier and customer
  • Description of quantity and type of goods supplied, or type and extent of services rendered
  • Date of transaction (or payment)
  • VAT rate applied and VAT amount payable

With the implementation of mandatory e-invoice, additional data points are required to comply with the invoice schema.

Unit price of goods or services

The standard VAT rate in Poland is 23%, though certain goods and supplies have reduced rates of 8% and 5% and some services are exempt from VAT altogether.

The VAT registration threshold for companies established in Poland is PLN 200,000.

There is no threshold on the VAT registration for foreign companies not established in Poland; they are required to register for VAT prior to making their first VAT-relevant supply in the country.

VAT applies to the supply of goods and rendering of services in Poland for consideration. VAT liability is money owed to the tax authority and is calculated by subtracting credits from the total amount of VAT a taxpayer has collected at the moment the VAT becomes chargeable.

The deadline for making the relevant VAT payment is the same as for submitting the VAT return part of the SAF-T, i.e., by the 25th day of the month following the month in which the tax point arises. VAT liabilities must be paid by bank transfer and in Polish zloty.

The Polish Tax Authorities require businesses established outside of the EU and having a VAT registration in Poland to appoint a fiscal representative in Poland. The fiscal representative can be an individual or a company, such as Sovos. The fiscal representative is jointly and severally liable with the taxpayer for the tax liability, which the fiscal representative settles on behalf of and for the benefit of that taxpayer in Poland.

It is worth noting that, since 23 February 2021, taxpayers established in Norway or Great Britain have not been obliged to appoint a fiscal representative when operating in Poland. The companies established in both Norway and Great Britain can register directly for VAT purposes in Poland. This entails that the legal representative of the company can sign the registration form without any involvement from the Polish established Company or an individual acting in the capacity of a fiscal representative.

An EU business is not required to appoint a fiscal representative to register for VAT in Poland, but it may choose to do so.

VAT applies to the following transactions in Poland:

  • The supply of goods and services within Poland for consideration
  • The export of goods outside of the EU
  • The import of goods from non-EU Member States
  • Receipt of reverse-charge services by a taxable person in Poland
  • Intra-Community supply of goods
  • Intra-Community acquisitions of goods from another EU Member State by a taxable person

The following activities are outside the scope of Polish VAT:

  • Transactions that cannot be subject to legal agreements (illegal transactions)

  • Sales of businesses (transfers of going concerns or part thereof)

The threshold for VAT registration for Polish-established businesses is PLN 200,000 (about EUR 46,000).

The VAT registration limit may apply either:

  • Retrospectively: The value of supplies of goods or services exceeded PLN 200,000 in the preceding tax year
  • Prospectively: At the start of business, the value of supplies of goods or services is expected to exceed PLN 200,000

Businesses operating in Poland may additionally opt to register for VAT regardless of reaching the threshold or if their operations comprise only VAT-exempt activities.

Non-established businesses – foreign businesses without a place of business in Poland – must register for VAT in Poland when making taxable supplies of goods or services in Poland. They are exempt from registration when they exclusively supply the following services:

  • Services and goods where the Polish purchaser pays tax under the reverse charge mechanism
  • Certain services that are subject to a zero rate (e.g., services supplied within Polish seaports, connected with international transport, services of air traffic control rendered for foreign providers of air transportation)

How Sovos can help with VAT compliance in Poland

The varied nature of tax obligations in Poland means compliance can be a resource-heavy task – especially when you consider the high probability of future updates and implementations. Choosing Sovos, a single vendor with global and local tax expertise, allows you to future-proof compliance.

Reclaim your time so you can focus on growing your business by speaking with our expert team today. Compliance is our concern.

VAT Compliance in Romania: An Overview for Businesses

Romanian VAT Compliance can be described as a layered system conflated with different declarations and requirements, from SAF-T obligations to electronic invoicing. In this page, businesses aiming to remain compliant and looking to know the most up to date news, can find an overview of the main Romanian VAT rules. Scroll down to learn about Romanian VAT compliance requirements and how to remain compliant.

Romania: General VAT information

Romania is a complex country for VAT rules, with many elements that companies need to be aware of. These include:

Periodic VAT return (Decont de taxa pe valoarea adaugata)

Monthly
25th day of the month following the end of the tax period

Quarterly
25th day of the month following the end of the tax period

Romanian Domestic Supplies & Purchase listing (Declaraţie informativă privind livrările/prestările şi achiziţiile efectuate pe teritoriul national – D394)

Monthly
30th day of the month following the end of the tax period

SAF-T (Declarației informative D406)

Monthly/Quarterly

SAF-T Stocks (Declarației informative D406)

On-demand – a minimum 30-day deadline

SAF-T Assets (Declarației informative D406)

Deadline for the submission of Financial Statements for the year

EU Sales and Purchases List

Monthly
25th day of the month following the end of the tax period

Intrastat

Monthly
15th day of the month following the relevant month

VAT rates

19%
9%
5%
0% and Exempt

Intrastat thresholds

Arrivals: RON 1 million
Dispatches: RON 1 million

VAT rules in Romania

Romania is at the forefront of VAT compliance, having implemented a broad range of requirements, from SAF-T obligations to e-invoicing. You can find more information on the various rules and requirements here:

Requirements to register for VAT in Romania

Taxable persons established in Romania are required to register for VAT purposes if their annual turnover exceeds the threshold RON 300,000 (EUR 88,500). Established entities that don’t meet the threshold may opt to register for VAT purposes.

Non-established entities are required to register for VAT purposes, regardless of annual turnover, when practicing certain activities such as Intra-Community transactions or exports.

When does VAT liability apply in Romania?

In Romania, VAT liability encompasses various transaction types – including, but not limited to, the following:

  • Supplies of goods and services for consideration with place of supply in Romania
  • Imports of goods
  • Intra-Community acquisitions of goods

Invoicing requirements in Romania

Legislation in Romania states that invoices, paper or electronic, must include the following information:

  • Invoice unique serial number
  • Invoice/delivery date
  • Supplier identification
  • Recipient identification (when they are taxable subjects as well)
  • Description of the goods or services provided
  • Taxable amount
  • Applicable tax rate

Since January 2024, the Romanian B2B e-invoicing and e-reporting mandate has applied to established taxpayers and VAT registered entities – concerning all B2B transactions with place of supply in Romania.

From January 2024, VAT-registered entities must report their invoices (regarding domestic B2B transactions) to the RO e-Factura platform within five working days of issuance.

Established taxpayers are equally required to electronically report their invoices from January 2024.

The tax authority provided a three-month grace period where no penalties will apply, meaning that penalties will be imposed from April 2024.

From July 2024, the e-reporting obligation will shift to an e-invoicing requirement for transactions between established taxpayers. If established taxpayers fail to issue the invoice electronically, the invoice must be reported within five calendar days to the RO e-Factura platform.

In addition to the invoicing content requirements, which must also be included in electronic invoices, the e-invoice must comply with certain technical requirements as well.

You can find more information about Romania’s e-invoicing rules on our dedicated Romania e-invoicing page.

Registration for OSS in Romania

The EU established the One Stop Shop (OSS) in July 2021, implementing an EU-wide 10,000-euro threshold for VAT and simplifying cross-border online sales in the region simpler. This is part of the EU VAT e-commerce package.

Following the applicable Romanian VAT rules, the following fall within the scope of the OSS regime:

  • Entities established in Romania
  • Non-EU taxable persons with a fixed establishment in Romania
  • Entities which have fixed establishments in more than one EU Member State including Romania)

These entities may choose Romania as their Member State of registration for OSS purposes.

Non-EU entities, which do not have a fixed establishment in the European Union, may also register in Romania for OSS purposes – only if carrying out distance sales of goods when the goods are dispatched from Romania or any other EU Member State.

In addition to the OSS registration, taxable persons may also apply to the Import One-Stop Shop (IOSS) in Romania which concerns B2C distance sales of goods from outside the region.

Intrastat, EU Sales and Purchases List and Domestic Supplies & Purchase listing (form 394) in Romania

Intrastat returns – which are related to the movement of goods in the European Union – are submitted in Romania if the taxable person exceeds the provided threshold.

Even though Intrastat requirements remain similar across the EU, each Member State may implement rules differently. Our Intrastat Guide is a useful tool for navigating cross-border trading in the EU.

In Romania, the Intrastat threshold for both arrivals and dispatches of goods is RON 1,000,000 (around EUR 201,000). The Intrastat return must be submitted by the 15th day of the following month.

The EU Sales and Purchases List is submitted in Romania by taxable persons carrying out Intra-Community supplies or purchases of goods or certain services. The return must be submitted by the 25th day of the following month and is not required to be submitted in tax periods where no transactions occurred.

The Domestic Supplies & Purchase listing (form 394), first implemented in July 2014, is an additional return to be submitted periodically by all VAT-registered entities in Romania. The return includes data on domestic supplies and purchases between VAT-registered entities and must be submitted by the 30th day of the month following the end of the tax period.

FAQ VAT compliance in Romania

In Romania, any entity subject to taxation (not just VAT) shall receive a tax identification number.

The number of digits in the VAT number may vary.

The Romanian periodic VAT return – Decont de taxa pe valoarea adaugata – is submitted on a monthly or quarterly basis, if the taxpayers’ annual turnover remains below the equivalent in RON of 100.000 EUR. The returns must be submitted electronically by the 25th day of the month following the end of the applicable tax period.

The VAT return must include the amount of the deductible VAT as well as the VAT charged in the tax period.

Taxable persons established in Romania are required to register for VAT purposes if the RON 300.000 (EUR 88.500) annual turnover threshold is exceeded. There is no threshold for non-established entities.

The Romanian VAT Act is part of the Fiscal Code (Codul Fiscal) of 8 September 2015, adopted by Law no. 227/2015.

The applicable VAT rates in Romania are 19%, 9%, 5% and 0%.

As a rule, the standard rate of 19% applies to all supplies of goods and services.

The reduced rates of 9% and 5% are only applicable to certain specifically identified goods and services. The 9% rate applies to:

  • Medicines for human and veterinary use
  • Food supplies
  • Hotel accommodation
  • Restaurant and catering

The reduced rate of 5% is applicable to:

  • Books, newspapers, magazines and school manuals
  • Access to museums, castles, cinemas, zoological and botanical gardens
  • Passenger transport

Exceptionally, certain transactions are taxable at a 0% rate, namely:

  • Exports of goods
  • Intra-community supplies of goods

Romania’s VAT rules provide reduced VAT rates of 9% and 5%, depending on the goods and services in question.

Taxable persons not established in the EU that fall under the obligation to register for VAT purposes in Romania are obliged to appoint a fiscal representative.

Yes. Since January 2023, Romania‘s mandatory e-transport system has monitored the transport of certain goods in the national territory. The e-transport system operates in parallel with Romania’s e-invoicing system. For more information read our in-depth blog about the e-transport system in Romania.

Help for VAT compliance in Romania

Looking back at this overview, it becomes clear just how fast-paced Romania’s developing VAT compliance requirements are. Sovos helps customers navigate difficult VAT compliance landscapes worldwide, by leveraging our global coverage.

We take care of compliance so you can concentrate on growing your business.

In less than six months, Poland is going to introduce its long-awaited CTC clearance e-invoicing mandate – a tax reform that will impact a large amount of businesses.

It has been possible to issue and receive e-invoices voluntarily via Krajowy System E-Faktur (KSeF) since January 2022, but from 1 July 2024 it will become mandatory for suppliers and buyers that are in scope of mandatory e-invoicing to do this via KSeF.

A detailed understanding of the new regime, plus timely and proper preparation, is critical for compliance. Whilst there is a six-month grace period on financial penalties, non-compliance can negatively impact your business in many other, often unexpected, ways.

In this 45-minute deep-dive webinar, Marta Sowińska from our Regulatory Analysis and Design team will cover:

Join us on 8 February at 2pm GMT | 3pm CET for a thorough review of the Polish KSeF e-invoicing mandate and the opportunity to submit your questions.

Register today

As tax authorities continue to digitize processes in their mission to reduce fraud and close their VAT gaps, they are introducing requirements that provide greater visibility into a company’s financial operations in the form of Continuous Transaction Controls (CTC).

It would be a mistake to think that being prepared to meet obligations in one of the countries where you operate can simply be replicated in another – CTCs are far from a ‘one-size-fits-all’ solution.

Join us on 24 January 2024 in our latest quarterly VAT Snapshot webinar series where regulatory experts Dilara Inal and Marta Sowinska will examine how tax authorities in Poland, Romania, Israel, Greece and Spain – all simultaneously implementing CTC regimes – are doing so with different sets of requirements.

Don’t miss this opportunity to learn more about these unique regimes and what they mean for your business.

Register now.

Poland SAF-T framework

Poland is one of many countries to use the Standard Audit File for Tax (SAF-T) to streamline tax compliance and reporting for businesses. The country was one of the first in Europe to replace the traditional VAT return with SAF-T.

Poland introduced its version of SAF-T, known as Jednolity Plik Kontrolny (JPK), in 2016, making monthly submissions of JPK_VAT compulsory for all taxpayers in 2018.

In 2020, JPK_VAT combined with the VAT return and is submitted with a declaration per the frequency of the VAT Return (monthly or quarterly).

Submission of the remaining seven JPK structures is upon request of the tax authority in the event of an audit.

Please note: JPK_VAT with the declaration is in the process of changing as a result of the introduction of mandatory e-invoicing via KSeF in Poland.

The legal framework of SAF-T in Poland

The Poland SAF-T framework consists of eight JPK structures:

JPK_V7M/K

declaration for records of VAT purchases and sales combined

JPK_FA

for VAT and VAT invoices

JPK_WB

for bank statements

JPK_PKPIR

for revenue and expense ledger

JPK_EWP

for revenue account

JPK_KR

for accounting books

JPK_MAG

for warehouses

JPK_FA_RR

for flat rate VAT invoices

Other than the monthly or quarterly periodic submission of JPK_V7M/K, submission of all other JPK structures is on demand.

However, from 1 January 2025, reporting of JPK EWP, JPW PKPIR, and JPK_KR will become a periodic reporting obligation.

Timeline SAF-T in Poland

  • 1 July 2016: SAF-T introduced in Poland in the form of JPK files
  • 1 January 2018: Poland mandated JPK_VAT for all taxable persons
  • 1 July 2018: Taxpayers must be able to produce accounting documents in JPK structures
  • 1 October 2020:  JPK_VAT with declaration consolidates the VAT Return and JPK_V7M/K
  • 1 July 2021: Amendments to the mandatory JPK_V7M/K adopted
  • 1 January 2022: Amendments to the JPK_V7M/K structure including changes to better align it with the EU VAT e-Commerce package
  • 1 January 2025: Reporting of JPK EWP, JPW PKPIR, and JPK_KR becomes a periodic obligation

Understanding JPK VAT and SAF-T in Poland

One of the eight JPK structures in Poland is JPK_VAT, a declaration combining VAT purchase and sales records. As of 2020, JPK_VAT must be sent alongside VAT returns to the tax authority.

JPK_VAT with the declaration has two variants, depending on the submission frequency of the VAT return:

  • JPK_V7M for taxpayers settling VAT monthly.
  • JPK_V7K for taxpayers who settle VAT quarterly.

Submission of JPK_V7M and JPK_V7K is on the 25th of the month following the reporting period.

The other SAF-T JPK structures for VAT are JPK_FA for VAT invoices and JPK_FA_RR for flat-rate VAT invoices. JPK_FA and JPK_FA_RR are both submitted on demand.

Implementing SAF-T as a business

SAF-T requires additional data to analyse and authenticate the accuracy of documentation. All data submitted in the SAF-T consolidated submission must be accurate and complete to ensure compliance.

Data for SAF-T requirements is often extracted from multiple sources for a single report and combining this data can be difficult.

The data required for SAF-T differs significantly from other reporting obligations that businesses might be familiar with. The XML format required for reports makes it difficult to review, compare or test reports ahead of submissions.

Other requirements for VAT compliance in Poland

As well as Poland’s SAF-T requirements, taxpayers need to also be aware of the KSeF e-invoicing mandate. Poland’s continuous transaction control (CTC) e-invoicing system is mandatory as of 1 July 2024, expanding to VAT-exempt taxpayers in 2025. Read this overview for a general introduction to Poland VAT compliance.

FAQ

JPK_VAT with a declaration is an electronic document that includes both VAT records, combining information on purchases and sales and VAT returns (VAT-7M and VAT-7K).

JPK_VAT is submitted on a monthly or quarterly basis.

Yes, SAF-T is mandatory in Poland. JPK VAT with a declaration must be sent to the tax authority on a periodic basis, while other types of JPKs are sent on demand.

Failure to comply with the SAF-T requirements in Poland can lead to penal and fiscal sanctions, based on a misdemeanor or a felony. If the value of the reduction of the tax liability exceeds PLN 10,000, it is a crime.

Submission of JPK_VAT with the declaration (JPK_V7M and JPK_V7K) is on the 25th day of the month following the reporting period. Other JPKs are submitted to tax authorities within three days after receiving a request from the tax authority.

Our Solution capabilities for Poland SAF-T

Data Extraction

Painlessly aggregate and consolidate data from a wide range of source systems complying with Poland’s SAF-T requirements including JPK files.

More about data extraction

Data Analytics

Check the accuracy, integrity and quality of complex data structures required by Poland SAF-T to give you peace of mind before you submit your JPK files to the tax authority.

More about data analytics

File Generation

Ensure that all required data sets from accounting entries, sales and purchase transactions, asset depreciation, stock movements and more, are mapped seamlessly into Poland’s JPK schema, ready to be analyzed and submitted to the tax authority.

More about file generation

Get the information you need

The convergence of traditional Value Added Tax (VAT) and transactional compliance regimes is creating new obligations and responsibilities for companies doing business around the world. When it comes to VAT, compliance is so much more than just reporting.

Here are six pitfalls you should avoid in the pursuit of VAT compliance:

 

1. Making the wrong VAT decision at the outset

Companies with multijurisdictional supply chains must ensure their VAT determination decisions are accurate every time. Managing the validation process with VAT Determination software that checks validity before invoices are cut can save time and improve data accuracy from the outset.

It’s also best practice to complete your buyer VAT ID checks at this point in the process to avoid nasty surprises later. Checking manually can be incredibly resource-intensive so using a solution that can automate this for you can save both time and hassle.

 

2. Not having a legally valid invoice

To be considered legal for VAT purposes, invoices need to meet a specific set of requirements which vary by jurisdiction. Without legally valid invoices, you may be presented with a host of problems when the time comes to reclaim input VAT. If you have accepted an invoice that doesn’t tick the boxes that make it legal for VAT purposes, you invite the scrutiny of the tax authorities.

Aside from possible fines, the delay while anomalies are reviewed can impact your cash flow and cause reputational damage. Even in a paper world, VAT deduction is not permitted for improperly formatted invoices.

 

3. Missing reporting deadlines

With VAT obligations always growing and adapting, the pressure on internal tax teams is greater than ever. Each government has its own approach to penalties for late submissions or overdue payments. Manual processes can no longer be relied upon to meet the demands of the authorities on time, and with accuracy.

It’s possible to streamline the reporting process using software, outsourced services or a hybrid approach; what’s best for your business depends on how your tax team is organised.

 

4. Manual error

With new requirements coming thick and fast, teams are working harder and faster. As a result, opportunities for manual error are at an all-time high.

Manually processing VAT invoices can be incredibly time-consuming and leaves room for oversight and human error. Even individual errors can lead to bigger problems down the line, attracting the attention of the authorities and impacting your ability to do business.

 

5. Challenges with data extraction and mapping

Extracting the right data from the appropriate system modules, and then processing and mapping it so that it can be summarised, is a complicated and detailed task. To complicate matters further, each jurisdiction has its own unique reporting requirements you must meet. Automating these processes can improve accuracy and your ability to comply.

 

6. Not reviewing data prior to submission

Preparing VAT Returns, EC (European Commission) Sales Lists, Intrastat Declarations and other country-specific reports for regular submission can be demanding. Add in the need to prepare a SAF-T (Standard Audit File for Tax) report and the complexity intensifies. SAF-T requirements differ by country, including transactional data (about sales and purchases) and accounting data at a minimum, but often need information about assets and inventory as well.

Combining detailed data from different source systems with an exacting submission format means the report cannot be easily eyeballed to check for possible errors. Tax Authorities use software to analyse the SAF-T filings   they receive and decide where to follow up with further auditing. To safeguard the quality of the submission and avoid a call from the tax authority, it’s essential that data is thoroughly analysed before it’s submitted – ideally using tools of the same calibre that each Tax Authority is using.

 

It’s never been more important to seek the right advice for VAT. Admitting you need help can be a daunting but crucial step, but the fear of non-compliance should be a bigger concern.

Simply put, there comes a time for every multinational organisation when managing complex tax obligations in-house just isn’t viable anymore. Consolidating your compliance with Sovos gives you access to industry-leading software, consulting services and regulatory experts, all of which are focused on ensuring you’re compliant now and will remain so in the future.

To find out more, get in touch today.

Infographic

The Tax Authorities are in Your Data

A reactive or ad hoc approach to tax compliance across the markets you do business in can mean the authorities have a better overall view of your data than your own internal teams. How confident are you that you have the same view of your data as the tax authorities?

EU-based companies must grapple with VAT charges on a myriad of goods transactions within the EU. As a manufacturing company, this intricate web of varying VAT rates can pose significant challenges. Choosing the right EU entry point is a pivotal decision, complicated by each country’s unique VAT regulations. Compounding the complexity, you may not always know the precise location of your goods in transit.

Manufacturers face supply chain disruptions, potentially jeopardising their already sophisticated operations. The question is, where should you commence your VAT journey?

Our VAT expert Russell Hughes guides you in this immersive webinar, where you will gain insights into:

Join us on this transformative journey through the VAT labyrinth and gain a competitive edge in the EU market. Don’t miss this opportunity to optimise your expansion strategy.

 

Register now.