Import of services and reverse charge: VAT settlement in 2026

An import of services arises where a Polish firm buys a service from a foreign supplier who has no Polish seat and no fixed establishment in Poland, and the place of taxation of that service is Poland. The foreign supplier issues an invoice without Polish VAT, and the tax is settled by the buyer — by reverse charge. An active VAT payer reports the same tax as output and input tax, so usually nothing is paid in addition; a VAT-exempt firm, however, must pay it out of its own pocket.

When a purchase from abroad is an import of services

The obligation to settle VAT by the buyer arises where, cumulatively:

1. the service provider is a taxable person without a seat and without a fixed establishment in Poland (and for services connected with real estate — is not registered for VAT in Poland either),
2. the buyer is a taxable person within the meaning of the VAT Act — i.e. any entrepreneur, including a VAT-exempt one, or a legal person registered for VAT UE,
3. the place of supply is in Poland. For services to firms, the rule is the buyer's place of seat, so this concerns most services: online advertising, SaaS software, hosting, advisory, translation, licences or programming work.

It does not matter whether the supplier is from the European Union or outside it. Exceptions are services with a special place of supply, e.g. connected with real estate located abroad or accommodation in a foreign hotel — then the tax is settled in the country where the real estate is located, and is usually paid by the local provider.

Settlement step by step for an active VAT payer

1. Determine the date of the tax obligation. As a rule, it is the day the service is performed, not the invoice or payment date. For services settled in periods, e.g. a monthly subscription, the service is deemed performed at the end of each settlement period.
2. Convert the currency. The amount from the invoice is converted at the average NBP rate from the last working day preceding the day on which the tax obligation arose. The Act alternatively allows the ECB rate to be chosen, and the chosen method is worth applying consistently to all transactions.
3. Charge the tax at the Polish rate proper for the given service — in most cases 23%.
4. Report output VAT in the records and the return (JPK_V7M or JPK_V7K) for the period in which the tax obligation arose.
5. Deduct the same tax as input tax in the same period, if the purchase serves taxable activities. The condition is that the output tax has been reported in the return in which it should have been settled. If the import of services is reported late, the return for the correct period must be corrected.

The return is filed by the 25th day of the month following the settlement period. If the 25th falls on a Saturday or a non-working day, the deadline moves to the nearest working day.

Example: subscription for cloud services

A programmer running a sole proprietorship and being an active VAT payer buys hosting from an Irish company for EUR 500 per month. The settlement period is a calendar month, and the invoice for March 2026 is dated 31 March.

• The tax obligation arises on 31 March (end of the settlement period).
• The NBP rate is taken from 30 March. At an example rate of PLN 4.25 the base is PLN 2,125.
• Output VAT: 23% × PLN 2,125 = PLN 488.75. The programmer reports the same amount as input VAT.
• Both amounts go into JPK_V7M for March. Because 25 April 2026 is a Saturday, the return can be filed by Monday 27 April.

The effect in VAT is zero, but skipping the import of services is an error in the return, which on inspection may result in correction and sanctions.

Import of services at a VAT-exempt firm

The turnover-based exemption (in 2026 up to PLN 240,000 of annual sales) does not relieve from settling the import of services. The exempt entrepreneur:

• before the first purchase of services from an EU counterparty must register as a VAT UE payer and quote the number with the PL prefix — otherwise the foreign supplier may charge their own tax;
• charges Polish VAT on the purchased service and pays it to the tax office, usually on the basis of the simplified VAT-9M return, filed for the month in which the tax obligation arose;
• has no right to deduct, because they do not perform taxable activities — the tax becomes a real cost for them.

In the hosting example, a VAT-exempt programmer would pay PLN 488.75 of tax each month that they cannot recover. For large purchases of advertising or software abroad, it is worth calculating whether registration as an active VAT payer would not be more favourable. VAT UE registration is described in the article on the VAT-R form and VAT UE registration.

Most common mistakes

• Treating a no-VAT invoice from a foreign firm as having "no tax significance".
• Settling the import of services on the payment date or the invoice-receipt date instead of the service-performance date.
• Using the rate from the payment day instead of the rate from the working day preceding the tax obligation.
• No VAT UE registration by exempt firms buying services in other EU countries.
• Treating purchases from large foreign advertising platforms as domestic purchases just because the payment is in zloty.

How Good Balance can help

As part of full accounting, we identify the import of services in purchase documents, convert currencies and report transactions in JPK_V7 in the correct period. We also help document foreign sales and purchases in line with the rules of VAT invoicing, and for exempt firms — carry out VAT UE registration.