Do I Need to Register for VAT in Poland?
Zbigniew Makowski
Licensed Polish Tax Advisor
- Tax Advisor registration no. 11 722
- More than 15 years of experience in VAT
- Former Polish Ministry of Finance official - Deputy Director of the VAT Department
Published: September 2026 · Last updated: September 2026
A foreign company may need to register for VAT in Poland even if it has no company, office or employees in Poland.
The key question is not where your company is established, but what transactions it carries out in Poland.
Polish VAT registration may be required, for example, if your company stores goods in Poland, moves its own goods to Poland from another EU country, imports goods into Poland or makes certain supplies that are taxable in Poland.
However, doing business with Polish customers does not automatically mean that you need Polish VAT registration.
The VAT treatment depends on your actual transaction model.
When does a foreign company need to register for VAT in Poland?
There is no single rule saying that every foreign company doing business in Poland must obtain a Polish VAT number.
The first step is to determine whether your transactions create VAT obligations in Poland and, if they do, whether Polish VAT must actually be accounted for by your company.
Here are some of the most common situations that should be checked.
Selling goods located in Poland
If your company owns goods located in Poland and sells them to customers from Polish stock, the transaction may constitute a domestic supply in Poland.
This can create a Polish VAT registration obligation.
However, the status of the customer and the specific transaction structure also matter. In some situations involving a foreign supplier, VAT may be accounted for by the customer rather than by the supplier.
Storing goods in a warehouse in Poland
Simply using a warehouse in Poland should not be analysed in isolation.
The important questions are how the goods arrive in Poland and what happens to them afterwards.
For example, if an EU company transfers its own goods from another EU country to a warehouse in Poland and subsequently sells them from Polish stock, the movement of the company's own goods can itself have VAT consequences.
This is why fulfilment and warehouse arrangements are one of the situations in which foreign companies should analyse their Polish VAT position before starting operations.
Moving your own goods to Poland from another EU country
You do not necessarily need to sell goods to a Polish customer for a Polish VAT obligation to arise.
Consider a German company that moves its own stock from Germany to Poland.
For VAT purposes, a transfer of a company's own goods between EU Member States may be treated as an intra-Community transaction, subject to specific exceptions and simplifications.
Consequently, moving inventory to Poland may create a Polish VAT registration requirement even before the goods are sold to the final customer.
Importing goods into Poland
If goods enter the EU from a non-EU country through Poland, you need to determine who is the importer, which customs procedure is used and what happens to the goods afterwards.
Importing goods into Poland does not automatically mean that the importer will need to register for Polish VAT.
For example, goods may enter Poland and subsequently leave Poland or be transported to another country. Depending on the transaction structure and the customs procedure used, the VAT consequences can be different.
Therefore, if your business model involves importing goods into Poland and subsequently moving or selling them outside Poland, the entire flow should be analysed before deciding whether Polish VAT registration is required.
In particular, the analysis should cover:
who acts as the importer,
which customs procedure is used,
where the goods are located when they are sold,
where the goods are transported after importation,
and how the subsequent supply is treated for VAT purposes.
Import through Poland followed by the removal of the goods from Poland does not, by itself, answer the VAT registration question.
Buying goods in Poland and selling them in Poland
A foreign company may purchase goods in Poland and subsequently resell them without moving the goods outside Poland.
This can create a domestic Polish supply.
Whether the foreign seller must register and account for Polish VAT will depend, among other things, on the type of transaction and the status of the customer.
Providing services to Polish businesses
Services require a different analysis from goods.
Under the general B2B rule, services are normally taxable where the business customer is established. For many ordinary B2B services supplied by a foreign business to a Polish business, VAT is therefore accounted for by the Polish customer under the reverse-charge mechanism.
For example, a French consulting company providing ordinary consulting services remotely to a Polish business will not generally need Polish VAT registration merely because its customer is located in Poland.
However, there are important exceptions to the general B2B rule.
Services connected with immovable property in Poland
Services sufficiently connected with immovable property follow a special VAT rule.
If the relevant immovable property is located in Poland, the place of supply of the service is generally Poland. This rule applies to both B2B and B2C transactions.
Depending on the circumstances, it can apply to services such as construction work, architectural services concerning a specific property, on-site supervision, property valuation, accommodation or certain rights to use immovable property. Polish VAT rules implement this principle in Article 28e of the VAT Act.
But there is an important distinction:
having the place of supply in Poland does not automatically mean that the foreign service provider must register for Polish VAT.
A second question must be answered: who is responsible for accounting for the Polish VAT?
Depending on the circumstances, VAT may have to be accounted for by the foreign supplier or, in certain situations, by the customer under the applicable reverse-charge rules.
A foreign company providing services connected with Polish real estate should therefore determine:
whether the service is actually sufficiently connected with immovable property for VAT purposes; and
who is required to account for Polish VAT.
Only then can it be determined whether Polish VAT registration is necessary.
Does selling to Polish customers automatically require VAT registration?
No.
The location of your customer is only one part of the VAT analysis.
Suppose a French consulting company provides ordinary business consulting services remotely to a Polish company.
The fact that the customer is located in Poland does not, by itself, require the French consultant to register for Polish VAT. Under the general B2B rule, VAT will normally be accounted for in Poland by the customer.
Compare this with a company holding its own stock in a Polish warehouse and making supplies from that stock.
Both companies have Polish customers, but their VAT situations can be completely different.
Before deciding whether Polish VAT registration is required, you should therefore establish:
what you are selling,
whether you are selling goods or services,
where the goods are located,
where they are transported from and to,
whether the customer is a business or consumer,
who is responsible for accounting for VAT,
and whether a special VAT scheme or simplification applies.
Can I need Polish VAT registration without having a company in Poland?
Yes.
VAT registration and establishing a company in Poland are two separate issues.
A foreign company does not generally need to establish a Polish subsidiary simply because its transactions create Polish VAT obligations.
Conversely, the absence of an office, employees or subsidiary in Poland does not mean that Polish VAT obligations cannot arise.
A foreign legal entity can therefore become a Polish VAT taxpayer without establishing a separate Polish company.
What if my company has a fixed establishment in Poland?
A foreign company may also have important Polish VAT obligations even if it has no registered office or subsidiary in Poland.
One of the issues that should then be considered is whether the company has a fixed establishment for VAT purposes in Poland.
A fixed establishment is different from a company's registered office. Its existence depends on the actual business arrangements and the human and technical resources available to the business in Poland. It therefore requires a separate VAT analysis.
The existence of a fixed establishment can also affect the place of supply of B2B services.
Under the general B2B rule, services are normally taxable where the business customer has established its business. However, if services are supplied to a fixed establishment located in another country, the place of supply is the place where that fixed establishment is located. Polish VAT rules reflect this principle in Article 28b(2) of the VAT Act.
For example, a foreign company may have its registered office outside Poland but have a fixed establishment in Poland. If particular B2B services are supplied to that Polish fixed establishment, the place of supply of those services may be Poland.
The existence of a fixed establishment may also affect how other transactions are treated for VAT purposes and who is responsible for accounting for VAT.
Having no Polish subsidiary therefore does not necessarily mean that your business has no VAT presence in Poland.
If your company has personnel, technical resources or an operational structure in Poland, the potential existence of a fixed establishment should be checked as part of the VAT assessment.
Examples
Example 1: German company stores goods in Poland
A German company transfers its own goods from Germany to a fulfilment warehouse in Poland. The goods are subsequently sold from that warehouse.
The transfer of the company's own goods to Poland and the subsequent sales may create Polish VAT obligations.
Polish VAT registration may therefore be required.
Example 2: French consultant provides services to a Polish company
A French consulting company provides ordinary B2B consulting services remotely to a Polish company.
Under the general B2B place-of-supply rules, VAT will normally be accounted for by the Polish customer.
The fact that the customer is Polish does not, by itself, create a Polish VAT registration requirement for the French consultant.
Example 3: US company imports goods into Poland and moves them to another country
A US company imports goods into Poland and the goods subsequently leave Poland for another country.
The fact that customs clearance takes place in Poland does not, by itself, determine whether the company must obtain a Polish VAT registration.
The customs procedure, identity of the importer, subsequent movement of the goods and structure of the supply chain must first be analysed.
Import into Poland followed by removal of the goods from Poland requires analysis of the complete customs and VAT flow.
Example 4: Czech company buys and resells goods in Poland
A Czech company purchases goods that are already located in Poland and resells them without transporting them outside Poland.
This creates a Polish VAT issue because the goods remain in Poland.
Whether the Czech company itself must account for Polish VAT requires analysis of the specific transaction and customer.
Example 5: EU online seller sells goods to Polish consumers
An EU company sells goods cross-border to consumers in Poland but does not store those goods in Poland.
Depending on the business model, the company may be able to account for Polish VAT through the EU One Stop Shop (OSS) rather than obtaining a separate Polish VAT registration.
Again, the existence of Polish customers does not automatically mean that a Polish VAT number is required.
Example 6: Foreign company provides construction services in Poland
A foreign company provides construction services concerning a building located in Poland.
Because the services are connected with immovable property in Poland, their place of supply is Poland.
However, this does not by itself determine whether the foreign company must register for Polish VAT. It is still necessary to establish who is responsible for accounting for VAT under the rules applicable to the transaction.
Polish place of supply does not always mean Polish VAT registration for the supplier.
Example 7: Foreign company has a fixed establishment in Poland
A foreign company has its registered office outside Poland but maintains an operational structure in Poland that may constitute a fixed establishment for VAT purposes. It purchases B2B services specifically for that Polish operation.
If the Polish structure qualifies as a fixed establishment and the services are supplied to that establishment, Poland may be the place of supply.
The existence of a Polish fixed establishment can materially change the VAT treatment and should be assessed separately.
When may Polish VAT registration not be required?
A foreign company may carry out transactions connected with Poland without needing a separate Polish VAT registration.
Depending on the circumstances, registration may not be required where:
VAT is accounted for by the Polish customer under the reverse-charge mechanism,
the transaction can be reported through an applicable OSS scheme,
the transaction is not taxable in Poland,
the applicable customs procedure and subsequent movement of imported goods produce a different VAT treatment,
or another exemption or simplification applies.
There is also an important possibility for small businesses established in another EU Member State.
Under the EU SME scheme, an eligible EU business can, subject to the applicable conditions and turnover thresholds, use the VAT exemption for small enterprises in Poland without standard Polish VAT registration.
This is another reason why registration should not be the starting point of the analysis.
First determine the VAT treatment. Then determine whether registration is actually necessary.
What should you check before registering for VAT in Poland?
Before filing a VAT registration application, I recommend mapping the actual transaction flow.
In particular, establish:
What are you selling? Goods and services follow different VAT rules.
Who is your customer? A business and a consumer may lead to different VAT treatment.
Where are the goods located before the sale?
Are your goods stored in Poland?
Do you move your own goods to Poland from another EU country?
Do you import goods into Poland and, if so, who is the importer and which customs procedure is used?
Where are your services taxable?
Are any services connected with immovable property in Poland?
Could your business have a fixed establishment in Poland?
Can reverse charge, OSS, the SME scheme or another simplification apply?
Only after answering these questions can you reliably determine whether Polish VAT registration is required.
VAT registration should be the result of the analysis, not its starting point.
What if VAT registration in Poland is required?
If the analysis shows that your company needs Polish VAT registration, the next step is to prepare the registration.
Registration is generally made using the VAT-R form. The Polish tax authorities may also verify the information and documentation provided during the registration process. Official Polish guidance confirms that foreign businesses without a registered office or fixed establishment in Poland can register for VAT in Poland.
For a foreign company, the practical process may involve additional documentation concerning the company, its business activity and the transactions it intends to carry out in Poland.
Learn more about VAT registration in Poland →
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Frequently Asked Questions
Do foreign companies need to register for VAT in Poland?
Not always. A foreign company may need Polish VAT registration if it carries out transactions creating Polish VAT obligations, but the result depends on the transaction model. Reverse charge, OSS, the SME scheme, customs arrangements or other rules may mean that a separate Polish VAT registration is not required.
Do I need a Polish company to register for VAT in Poland?
No. VAT registration does not require you to establish a Polish company. A foreign legal entity can have Polish VAT obligations and obtain Polish VAT identification without establishing a Polish subsidiary.
Does selling to Polish customers require VAT registration?
Not automatically. You need to determine what is being supplied, where the transaction is taxable and who is responsible for accounting for VAT. For example, many ordinary cross-border B2B services are subject to reverse charge.
Does storing goods in Poland require VAT registration?
It can. In particular, moving your own goods from another EU country to stock held in Poland can create Polish VAT consequences. The precise warehouse and supply model should be analysed before the goods are moved.
Does importing goods into Poland require VAT registration?
Not in every case. You need to consider who acts as the importer, which customs procedure is used, what happens to the goods after importation and how subsequent transactions are structured.
Do services connected with Polish real estate require VAT registration?
Not automatically. Services sufficiently connected with immovable property located in Poland generally have their place of supply in Poland, but it is still necessary to determine who is responsible for accounting for VAT.
Does having a fixed establishment in Poland affect VAT?
Yes, potentially. A Polish fixed establishment can affect the place of supply of services and other VAT consequences. Whether a particular business structure constitutes a fixed establishment must be assessed based on the actual circumstances.
Can a foreign company use the Polish VAT exemption for small businesses?
Potentially yes. Eligible businesses established in another EU Member State may use the cross-border SME scheme in Poland, subject to the applicable conditions and turnover thresholds.
When should I register for VAT in Poland?
If registration is required, it should generally be addressed before carrying out the transaction that creates the relevant Polish VAT obligation. The exact timing depends on the transaction and the type of registration required.