Virtual office vs the tax office — when VAT deregistration bites

The tax office does not question the mere fact of using a virtual office. Problems start when it is impossible to reach the entrepreneur at the indicated address, data in registers diverge or the firm shows no activity for many months. The result may be deregistration from the VAT payers register, and in extreme cases also from CEIDG. Below we describe the warning signs and ways to avoid them.

What the tax office actually verifies

From the office's point of view, the virtual office address is an ordinary business address. What matters is not whether the entrepreneur works there every day, but whether:

• address data in CEIDG or KRS, in the VAT-R registration and on the White List of VAT payers are consistent;
• correspondence sent to that address actually reaches the entrepreneur or proxy;
• the entrepreneur appears when summoned or responds in time;
• it is known where the tax documentation is kept; audit activities are carried out at the audited entity's seat, the place where documentation is kept or in other places related to the activity.

Basic information on which addresses a firm provides in registers and what the service itself offers is in the article Virtual office for a business — what it offers and what it does not replace. Here we focus on situations in which the office address becomes a problem in the relationship with the tax authority.

When the tax office may remove the firm from the VAT register

The VAT Act allows the head of the tax office to remove a taxpayer from the register ex officio, without notifying them. For virtual offices, the key grounds are those arising from lack of contact or lack of activity:

• the taxpayer does not exist or, despite documented attempts, cannot be contacted;
• the taxpayer or proxy does not appear when summoned by tax authorities;
• data in the registration form turn out to be untrue;
• the taxpayer has not filed returns for 3 consecutive months or for a quarter;
• for 6 consecutive months or 2 quarters they filed returns with no sales and no purchases with VAT to deduct.

Removal is immediately visible on the White List, so counterparties may stop paying invoices or lose the right to deduct VAT. A firm without active VAT payer status also should not issue invoices with VAT. In most of these cases, however, there is a way back: within 2 months of removal an application can be filed to restore registration without a new VAT-R form, provided it is shown that the activity is actually conducted and the missing returns are filed.

End of the operator contract vs CEIDG and KRS entries

Every address entered in CEIDG must be backed by a legal title, and in the application for entry the entrepreneur declares they have it. When the contract with the operator expires and the entry remains unchanged, the owner of the premises may notify the minister responsible for the economy. The minister then calls on the entrepreneur to present proof of legal title or to change the address within 7 days of service of the summons. Lack of reaction ends with a decision to remove the entrepreneur from CEIDG.

The summons is sent to the address from the entry, i.e. often to the office that has just been given up. In an sp. z o.o. the seat is specified in the articles of association, and the address is entered in the KRS, so its change must be reported by application to the register court; a change of the town of the seat additionally requires an amendment of the articles of association. In both cases the new address must be reported before the old one stops operating.

Warning signs in practice

Most trouble arises not from the rules but from organisation. Pay attention to such situations:

• a contract without clear mail handling: the operator receives letters but does not scan them or inform about collection notices on the same day;
• no one can collect a registered letter, because the contract lacks a postal power of attorney for the operator;
• the address in several registers, of which only some were updated after moving to a new office;
• zero returns in a firm that is only building sales or waiting for a contract, without explaining this situation to the tax office;
• no information on where the documents are, when an inspector wants to start activities and there is neither the entrepreneur nor the books at the office address.

What to watch in the contract with the operator

1. Consent to indicate the address in CEIDG, KRS and VAT-R and a contract form allowing proof of legal title.
2. Scope of mail handling: receiving registered letters, scanning, notifications, forwarding originals.
3. A notice period sufficient to change the entry and inform offices and counterparties.
4. Treatment of letters after the contract ends, e.g. duty to forward them for a defined period.
5. Option to use a meeting room, if an office or counterparty wishes to meet at the firm's seat.

Example: an uncollected summons and removal from VAT

Mr Michał runs a sole proprietorship consulting firm with a virtual office address. In 2026 the operator received a registered letter from the tax office, but the notification went to an unused e-mail inbox. Mr Michał did not appear on the summons, and after another failed contact attempt the office removed him from the VAT register. He learned about it from a client who checked the White List before paying an invoice.

The remedial plan looked like this: contact the office and respond to the summons, file the application to restore registration before 2 months after removal, with evidence of running the activity (contracts, invoices, statements), correct contact data in the contract with the operator, and appoint a proxy for office contacts.

How Good Balance can help

We provide an address as part of the virtual office service with mail handling and help put data in order in CEIDG, KRS and VAT-R. For simplified accounting clients we help respond to summons and file applications to restore VAT registration.