When and how to file the VAT return in Poland

Who must file a VAT return in Poland?

The VAT filing obligation in Poland applies to any entity holding a Polish VAT number, with no distinction between residents and non-residents. For a complete overview, see our VAT rules in Poland guide. If your company is registered for VAT in Poland, whether it is French, German, American or Korean, it must file its periodic returns with the KAS (Krajowa Administracja Skarbowa, the Polish tax administration).

Resident companies vs foreign companies

Resident Polish companies and foreign companies registered for VAT in Poland are subject to the same filing obligations. The distinction does not rest on geographic origin, but on the filing format and the cases requiring prior registration.

For foreign companies, registration for VAT in Poland becomes mandatory as soon as the first taxable transaction takes place on Polish territory: storing goods, local sales, imports, intra-Community supplies dispatched from Poland. Once registered, the foreign entity files exactly the same JPK files as a Polish company.

Filing obligation even with no transactions (nil return)

An active Polish VAT number entails a filing obligation, even if no taxable transaction took place during the period. This nil return, called deklaracja zerowa in Polish, is mandatory. Neglecting this filing constitutes a filing offence sanctioned by the Urząd Skarbowy (the local tax office).

The special case of special schemes (VAT-8, VAT-9M)

Two special forms coexist alongside the JPK_V7M for specific situations:

• VAT-8: for entities not registered for active VAT (exempt in Poland) that make intra-Community acquisitions of goods exceeding the threshold of PLN 50,000 per year.
• VAT-9M: for entities that do not file a standard JPK_V7M but import services or acquire goods under the reverse charge.

These forms are also filed electronically, before the 25th of the month following the transaction concerned.

Monthly or quarterly: which filing frequency in Poland?

The general rule in Poland is the monthly return. The only exception: small taxable persons (mały podatnik) who may opt for the quarterly frequency. Both formats use the JPK system (Jednolity Plik Kontrolny, the Standard Audit File), which has replaced the former VAT-7 and VAT-7K forms since October 2020.

JPK_V7M, the monthly return (general rule)

The JPK_V7M is the monthly VAT return file. It applies to almost every company registered for VAT in Poland. This XML file combines into a single document:

• the sales ledger (ewidencja sprzedaży)
• the purchase ledger (ewidencja zakupów)
• the declarative part (deklaracja), formerly known as VAT-7

Merging these three elements into a single file is a feature of the Polish SAF-T system. It streamlines the KAS tax audits, which then have a complete view of output VAT and deductible VAT in a single submission.

JPK_V7K, the quarterly return (small taxable persons)

The JPK_V7K is reserved for small taxable persons whose annual turnover does not exceed roughly PLN 5,000,000 (about EUR 1.2m). These companies file:

• the ledgers (the ewidencja part) every month, before the 25th
• the declarative part (the deklaracja part) once a quarter, before the 25th of the month following the end of the quarter

How do you switch from monthly to quarterly?

Moving to the quarterly frequency is done by filing a declaration of choice with the competent Urząd Skarbowy. The change takes effect at the start of the quarter following the request. Small taxable person status must be reassessed each year: if your turnover exceeds the threshold, you automatically revert to monthly filing for the following year.

What is the deadline to file your Polish VAT return?

The universal deadline is the 25th of the month following the reporting period. This rule applies without exception to the monthly JPK_V7M returns, to the monthly JPK_V7K ledgers, and to the quarterly declarative part of the JPK_V7K.

The 25th of the month: the universal rule

The 25th-of-the-month deadline was introduced with the JPK_V7 reform of October 2020, which replaced the former deadline that applied under the old VAT-7 forms. Today, the 25th is the only date to remember for the Polish VAT return.

2025 deadline calendar

Table of reporting periods and filing deadlines:

Payment date for the VAT due

The VAT due (output VAT collected minus deductible VAT) is payable on the same date as the JPK_V7M filing: the 25th of the following month. Payment is made by bank transfer to the account of the competent Urząd Skarbowy. Foreign companies must hold a Polish bank account to make this transfer, an essential condition for managing their obligations directly.

How do you complete and file the JPK_V7 return in Poland?

The JPK_V7M is an XML file structured in two main parts, prepared in compatible accounting software, digitally signed and submitted to the podatkowy.gov.pl portal. Here is the full procedure.

Step 1: prepare the sales ledger (JPK part)

The sales ledger (ewidencja sprzedaży) lists every invoice issued during the period. For each invoice, you must enter:

• The customer's VAT number
• The taxable base per rate (23 %, 6 %, 13 %, zero rate)
• The corresponding amount of output VAT
• The GTU codes (Grupy Towarów i Usług) where applicable
• The specific procedure codes (TP for related-party transactions, MK for small taxable persons, and so on)

Step 2: prepare the purchase ledger (JPK part)

The purchase ledger (ewidencja zakupów) records every invoice received that gives a right to deduction. Each line shows:

• The supplier's VAT number, checked beforehand against the white list (Biała Lista) of VAT taxpayers
• The base and the amount of deductible VAT
• The date on which the right to deduction arises
• Where applicable, the split payment mechanism (mechanizm podzielonej płatności) if it applies

Step 3: complete the declarative part (former VAT-7)

The declarative part (deklaracja) is the tax summary of the ledger. It automatically picks up the ledger totals and calculates:

• Total output VAT (base plus amount per rate)
• Total deductible VAT
• The VAT balance: either an amount to pay, or a VAT credit to carry forward or refund
• The details of any refund requested (standard period of 60 days, accelerated period of 25 days where the conditions are met)

Step 4: sign and submit electronically

The finalised XML file must be digitally signed before submission. Two options:

1. Qualified electronic signature (kwalifikowany podpis elektroniczny), the standard solution for foreign companies, issued by an accredited provider
2. Profil zaufany (trusted profile), a free digital identity that nonetheless requires in-person activation at a Polish administration office

The signed file is submitted via the Ministerstwo Finansów podatkowy.gov.pl portal. In return, you receive a UPO (Urzędowe Potwierdzenie Odbioru, the official acknowledgement of receipt). Keep this UPO: it is your legal proof of filing. The files and their UPO must be archived for 5 years.

GTU codes: which goods and services require them?

The GTU codes (Grupy Towarów i Usług) are mandatory markers to apply to certain lines of your sales ledger. They allow the KAS to identify flows with a high tax risk.

Is there an annual VAT return in Poland?

No. Poland has no annual VAT return. Unlike France (CA12), Germany (Umsatzsteuerjahreserklärung) or Italy (dichiarazione IVA annuale), the Polish system provides for no separate annual summary. All VAT obligations are covered by the monthly JPK_V7M files (or the quarterly JPK_V7K files).

This feature is often a source of confusion for companies used to Western European systems. In Poland, the 12 (or 4) JPK files of the year make up the complete VAT tax return. There is nothing extra to file at year-end for VAT.

Penalties for late filing or non-filing of the VAT return in Poland

The Polish VAT penalty system has three tiers, combining administrative fines, late-payment interest and specific surcharges.

Administrative fines

For late filing or non-filing of a VAT return, the administrative penalties (kary karnoskarbowe) range from PLN 424 to PLN 84,840 per offence. The exact amount is assessed case by case according to the seriousness and any repeat offence.

For errors in the JPK file that are not corrected after a formal notice is received: PLN 500 per error.

Late-payment interest on unpaid VAT

How do you regularise an incorrect or late return?

Voluntary regularisation is always preferable to a tax audit. To correct a return already submitted:

1. File a corrective JPK_V7M via the same podatkowy.gov.pl portal, with an explicit mention of its corrective nature
2. Pay any additional VAT due, with interest calculated at the reduced rate of 7.25 % if the correction is made within 6 months
3. Settle the balance within 7 days of filing the correction to benefit from the reduced rate
4. Keep the UPO of the corrective file as legal proof

Can you file your VAT return in Poland yourself?

Technically yes, in practice difficult for foreign companies. Self-filing is possible but involves technical and administrative prerequisites that most non-resident entities cannot meet on their own.

Technical conditions for filing without an intermediary

To file the JPK_V7M on your own, your company must have:

• Access to the podatkowy.gov.pl portal with authentication
• A qualified electronic signature or a profil zaufany (activation requiring a physical presence in Poland)
• JPK-compatible accounting software able to generate the XML file in the correct schema
• A Polish bank account for VAT transfers

Why foreign companies turn to a fiscal representative

The technical complexity of the JPK, the language barrier and the lack of a physical presence in Poland lead almost every foreign company to delegate its returns to a fiscal representative in Poland. This agent handles the preparation and filing of the JPK_V7M/V7K files, the electronic signature, the follow-up of exchanges with the administration and the management of any audits.

Need help with your VAT returns in Poland?

Eurofiscalis handles JPK_V7M returns and fiscal representation in Poland for hundreds of French and international companies. From registration to the monthly return, including audits and VAT refund in Poland, our teams in Warsaw and Paris take on the entirety of your Polish VAT compliance. See also our guide on EC Sales List and Intrastat in Poland.

Book a meeting with a Poland VAT specialist to secure your compliance and delegate your JPK_V7M returns with complete peace of mind.