VAT Changes in Poland from 2027: VAT Warehouses and Wider Joint Liability

New VAT Warehouse Procedure

The Act of 4 September 2026 introduces a VAT warehouse procedure (“skład VAT”). Under this procedure, a 0% rate applies to:

• intra-Community acquisitions of goods placed in the warehouse;

• supplies of those goods between authorised users; and

• services directly related to the stored goods.

VAT becomes due when the procedure ends, for example, when the goods leave the warehouse or after 24 months of storage, and must be paid within 5 days. Exports and intra-Community supplies from the warehouse are excluded from this payment obligation.

Both the warehouse keeper and the procedure user need authorisation from the tax office. The keeper’s authorisation is indefinite; the user’s is valid for 36 months. Applicants must have been registered as active VAT taxpayers for at least 12 months and have no significant tax arrears.

Only goods listed in the new Annex 17 to the VAT Act qualify. These include agricultural products, chemicals, copper, nickel, precious metals and certain vehicles. Users must file a weekly summary of goods placed in the warehouse and a monthly declaration when the procedure ends.

Joint and Several Liability Extended to Services

From 1 January 2027, buyers may be held jointly liable for a supplier’s unpaid VAT on services listed in a new Annex 16, including:

• software and IT consultancy;

• accounting and management consultancy;

• advertising and market research; and

• employment services.

Liability applies only where the buyer knew, or had reasonable grounds to suspect, that the VAT would not be paid. It does not apply to payments made through the split payment mechanism or to invoices below PLN 15,000, unless monthly purchases from the same supplier exceed PLN 50,000.

Stricter Fiscal Representation Rules

For non-established businesses that must appoint a fiscal representative, VAT registration will be refused if no representative has been appointed. A taxpayer whose representative stops acting will be deregistered unless it appoints a new one. Registration can be restored if a new representative is appointed within 2 months of deregistration.

Other Changes and How We Can Help You

The amendments also adapt import VAT rules to supplementary customs declarations and introduce terminals for the electronic TAX FREE system at border crossings from 1 July 2028.

Separately, Poland plans to raise the VAT rate on certain non-alcoholic beverages to 23% from 1 January 2027.

Marosa by Wolters Kluwer can help you assess how the new VAT warehouse procedure and the extended joint liability rules affect your business, review your fiscal representation and VAT registration status in Poland, and manage your VAT compliance through VATify.  

For more on Polish VAT rules, see our Polish VAT manual, or get in touch with our team.