Poland Proposes Comprehensive Updates to VAT Rules
The Polish government has added to its legislative agenda a draft bill amending the VAT Act (2004) and the Act on the principles of registration and identification of taxpayers and payers (NIP Act). Expected to be adopted by the Council of Ministers in late 2025, the proposals aim to modernise VAT compliance, align with EU case law, and close loopholes identified by both authorities and businesses.
See more in our Polish VAT guide.
VAT Act Changes
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Agricultural taxpayers – Following a 2022 CJEU ruling, individuals engaged in agricultural activities on jointly owned property will be able to register as separate VAT taxpayers, ensuring compliance with EU law.
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Deduction rights – Amendments implement the 2023 CJEU ruling that VAT deductions cannot be denied solely because a transaction is deemed fictitious or invalid under civil law.
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0% VAT rate – The bill would allow a zero rate for certain insurance services and services linked to the import of VAT-exempt goods, where these are included in the taxable base.
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VAT groups – Rules will be corrected to ensure proper extension of VAT group, established in 2023, operation periods.
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Deposit return scheme – Clarifications will set consistent rules for applying VAT rates and for retention of records in packaging deposit systems.
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Bad debt relief – Adjustments ensure small taxpayers using the cash method can apply relief even if uncollectability arises before tax liability.
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Import of goods – Provisions will clarify use of Article 33a settlement simplifications, limit abuses related to false declarations, and restrict interest on customs-related debts.
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Taxpayer registration – Streamlined rules will allow refusals where key obligations (e.g., appointing a tax representative) are unmet and will simplify deregistration processes by eliminating VAT-Z duplications. Taxpayer VAT status will also become verifiable retrospectively for up to five years.
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Cash registers – New obligations will cover deregistration, disposal of old devices, and potential servicing requirements for virtual registers. A ban will be introduced on replacing fiscal memory in outdated models.
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International trade – A “VAT warehouse” system will be introduced, enabling the application of a 0% rate to certain cross-border transactions, in line with practices in other EU member states.
NIP Act Amendments
The draft also simplifies registration and identification procedures. Notably, form templates will be published online rather than by regulation, and the institution of NIP revocation will be strengthened with clearer grounds and streamlined procedures.
