When you buy digital/IT/marketing services from the EU or Ukraine, you have an import of services in Poland (reverse charge = the buyer self-accounts for VAT). Active VAT payer: report output VAT and — if eligible — deduct the same VAT as input (neutral). VAT-exempt business: report output VAT payable (no right to deduct), typically in the VAT-9M return.
What is an “import of services” (in simple terms)?
It’s when you, as a Polish business, purchase a service from a foreign supplier (EU or third country), and Polish rules say the VAT must be accounted for by the buyer in Poland (that’s you). Reverse charge means that not the seller but the buyer accounts for the VAT.
Purchases from the EU — steps
- Register for VAT-UE before the first purchase (Art. 28b): this also applies to businesses exempt from VAT.
- Supplier’s invoice: usually net (without local VAT) with the note “reverse charge” and your EU VAT ID.
- Settlement in Poland:
- Active VAT payer: report output VAT and — if the service is used for taxable activity — deduct the same amount as input VAT (financial effect zero).
- VAT-exempt business: report output VAT payable (no deduction) — typically on VAT-9M.
- Reports: you do not include imports of services in the EU Sales Listing (VAT-UE). Report them in JPK_V7 (active VAT payers) or VAT-9M (exempt).
Purchases from Ukraine — steps
- Invoice from Ukraine: usually net (no Polish VAT charged).
- Settlement in Poland (reverse charge):
- Active VAT payer: output VAT + (if eligible) input VAT = usually neutral.
- VAT-exempt business: VAT-9M and VAT payment.
- EU VAT ID: not applicable to transactions with Ukraine (third country).
Examples
- UX audit from Germany (B2B): German supplier → net invoice with “reverse charge” and your EU VAT ID. In Poland: you report output VAT; if you are an active VAT payer and the service is linked to taxable activity — you deduct the same VAT (neutral).
- Landing page coding in Kyiv: net invoice from Ukraine. In Poland: import of services; active VAT payer — neutral; VAT-exempt — VAT-9M payable.
Import checklist
- [ ] Confirm it’s B2B and that Art. 28b applies.
- [ ] EU: register/verify your EU VAT ID before the first purchase.
- [ ] Invoice: net + (for EU) reverse charge + your EU VAT ID.
- [ ] Settlement in Poland:
- active VAT payer → JPK_V7 (output + input VAT),
- exempt → VAT-9M (VAT to pay).
- [ ] Do not include imports of services in VAT-UE (VAT-UE is mainly for sales of services to the EU).
Common mistakes
- No VAT-UE registration before the first EU purchase (Art. 28b).
- Including imports of services in the VAT-UE listing — this is incorrect.
- “The invoice is net, so I don’t have to do anything” — you must account for VAT under the reverse charge mechanism.
- No right to deduct for VAT-exempt businesses — that is a real cost (plan ahead).
FAQ
As a VAT-exempt business, do I need an EU VAT ID for EU purchases?
Yes. To purchase services from the EU (Art. 28b), you need an EU VAT ID and must register before the first transaction.
Do I report imports of services in VAT-UE?
No. Imports of services are reported in JPK_V7 (active VAT payers) or VAT-9M (exempt). VAT-UE relates, among others, to sales of services to the EU.
Do I need an EU VAT ID for purchases from Ukraine?
No. The EU VAT ID is only for transactions within the EU.
When does the tax obligation arise?
Generally on completion of the service or receipt of payment (an advance may matter). Confirm exact dates and periods with your accountant.
How do I convert foreign currency to PLN?
Use the appropriate exchange rate (typically the day preceding the tax point). Confirm the practice with your accounting team.
Notes and risks
- Fixed establishment (FE) in Poland on the foreign supplier’s side can change the place of taxation (rare, but important for groups/SSCs).
- Special services (real estate, events) have different place-of-taxation rules.
- Advances and continuous services — pay attention to the tax point.
Disclaimer
This material is informational. It is not tax advice. Rules change — coordinate your actions with your accountant/advisor (especially for first-time transactions and when operating under VAT exemption).
Need help?
Contact Most Biznesu — they can assist with registrations (VAT-UE/OSS) and ongoing settlements.
Questions? Leave a message via the form — we’ll reply.