The sale of a product to a contractor from a third country is not always an export for VAT purposes. The goods must be transported from Poland outside the territory of the European Union, and the export should be confirmed by the competent customs authority.

The export of goods outside the European Union may benefit from the 0% VAT rate, but only after the conditions concerning transport and documentation have been met. Of particular importance is the moment when the message confirming the exit of the goods is received. The absence of such evidence does not rule out the preferential rate, but it may require the temporary application of the domestic rate.

The most important information from the article

• the tax liability in exports generally arises on the date of the supply, and not on the date of customs clearance;
• the primary proof of export is the electronic IE-599 message;
• the 0% rate depends on receiving a document confirming that the goods have left the EU;
• exports are reported in the records and declaration sections of JPK_V7;
• the provision of services to a foreign contractor is settled according to different rules than the export of products.

What constitutes an export of goods for VAT purposes?

An export is a supply combined with the removal of goods from Poland outside the EU. The foreign address of the purchaser alone is not sufficient.

The VAT Act distinguishes between direct export, where the transport is organised by the supplier or an entity acting on its behalf, and indirect export, where the export is organised by the foreign purchaser. In both cases, there must be a connection between the specific supply and the movement of the goods outside the Union.

For example, the sale of a machine to a Ukrainian company will constitute an export if the machine leaves Poland for Ukraine. However, if the customer collects the equipment and uses it in a warehouse in Poland, there will be no export, even though the invoice was issued to a foreign entity.

Who is the exporter in the customs procedure?

The exporter is the entity indicated in the export declaration. It does not always have to be the seller shown on the invoice.

The phrase “exporter definition” refers primarily to EU customs regulations and not to a separate category of taxpayer under the VAT Act. As a rule, the exporter is a person established in the customs territory of the EU who decides to remove the goods from that territory. If such an entity cannot be indicated, it may be an EU participant in the agreement under which the export takes place.

It is worth distinguishing three roles: the seller, the customs exporter and the declarant. They may belong to one company, but the customs declaration may also be submitted by a representative, for example a customs agency.

Export of goods – tax liability – when does it arise?

As a rule, the date on which the supply of the goods is made is decisive. The date of issuing the invoice or receiving IE-599 does not postpone this moment.

In the case of the phrase “tax liability on the export of goods”, the most important rule is that VAT is recognised at the moment when the right to dispose of the goods as owner is transferred. If the machine was handed over to the purchaser on 12 August, the tax liability may arise on that very day, even if customs clearance was completed on 14 August and the IE-599 message was received on 16 August.

In the case of an advance payment, the tax liability arises in respect of the amount received. The 0% rate may be retained if the export takes place within six months, counting from the end of the month in which the payment was received, and the taxpayer obtains within that period a document confirming the export. A later date is permitted where it is justified by the specific nature of the supply as defined in its terms.

What documents confirm the right to the 0% VAT rate?

The most important document is the official proof that the goods have left the EU. Normally, this will be the IE-599 message.

The document should make it possible to link the export with the invoice and the specific goods. The Act lists customs documents by way of example, therefore an alternative proof may be accepted if it unequivocally confirms the actual export. However, the safest solution remains IE-599 received from the system handling export declarations.

It is worth supplementing the transaction documentation with:

• the invoice and the purchase order or contract;
• the customs declaration with the MRN number;
• the IE-599 message;
• the CMR consignment note, AWB or bill of lading;
• proof of payment and correspondence with the purchaser;
• documents of origin, licences or permits, if required.

If the export confirmation does not arrive before the deadline for filing JPK_V7, the taxpayer may postpone reporting the supply to the following period, provided that they have a document confirming the commencement of the export procedure. The absence of IE-599 also in the following period means that the domestic rate must be applied. Receipt of the proof at a later date allows the VAT to be corrected in the settlement for the period in which the proof was received.

Export invoice – how should it be issued correctly?

The document generally contains the same data as an ordinary sales invoice. When the export conditions are met, the 0% VAT rate is applied.

An export invoice should identify the parties, the subject of the supply, the quantity, the price, the date of sale and the taxable amount subject to the 0% rate. It may be issued in a foreign currency, while the amounts required for JPK reporting must be converted into Polish zlotys according to the applicable tax exchange rate.

In 2026, invoices documenting exports issued by Polish taxpayers subject to the e-invoicing obligation are issued in KSeF. The document must then be provided to the foreign recipient in an agreed manner, as the recipient does not have to have access to the Polish system.

Pro tip: it is worth providing the invoice number in the customs declaration and retaining the MRN number when recording the invoice in the accounting system. This makes it easier to verify later whether the IE-599 concerns exactly the same supply.

How should exports of goods be reported in JPK_V7?

The taxable amount is entered in field K_22 of the records section. The total is then transferred to field P_22 of the declaration section.

Exports of goods in JPK are reported for the period in which the tax liability arose, taking into account the special rules applied while awaiting the export document. If the taxpayer has the required confirmation before filing the file, the taxable amount is reported at the 0% rate. The GTU designation should be added if the exported product belongs to the relevant group, e.g. a vehicle covered by GTU_07.

The mere issuance of an invoice with the 0% rate does not determine whether the settlement is correct. The data from the invoice, customs declaration, IE-599 and VAT records should be consistent with one another in terms of the goods, value and parties to the transaction.

Is the export of services outside the EU settled in the same way as goods?

No, because services do not undergo customs clearance. First, their place of supply must be determined.

“Export of services outside the EU” is a colloquial term, because the VAT Act does not define a separate transaction under that name. For most B2B services, Article 28b of the VAT Act applies, according to which the place of taxation is the country where the customer is established. A Polish company providing a marketing service to a business in the USA therefore issues an invoice without Polish VAT, usually with the note “reverse charge”.

The export of services outside the EU is generally reported in field K_11 of the records section and P_11 of the declaration section of JPK_V7. Such sales should not be reported in K_12 and P_12, because these fields concern services under Article 100(1)(4) provided to taxpayers from other EU Member States. Before making the settlement, however, exceptions concerning, among other things, real estate, transport, admission to events or electronic services provided to consumers must be checked.

How should the sale of a company car to a customer outside the EU be settled?

Such a sale may constitute an export subject to the 0% rate. The foreign purchaser alone does not, however, provide the right to the preferential rate.

The sale of a company car outside the Union for VAT purposes requires confirmation that the vehicle actually left the EU as part of the supply. If the car is exported by the customer, this will usually be an indirect export, and the export document must make it possible to identify the vehicle, preferably by its VIN number.

The limited right to deduct VAT on the earlier purchase of the car does not exclude the application of the 0% rate on a subsequent export. However, vehicles sold under the VAT margin scheme or covered by a special exemption must be analysed separately. In JPK, the sale of a car classified under CN codes 8701–8708 generally requires the GTU_07 designation.

Is a sale to the United Kingdom an export?

A supply from Poland to England, Scotland or Wales is an export. Different rules may apply to trade in goods with Northern Ireland.

Following Brexit, the United Kingdom is a third country for the purposes of trade in goods, while Northern Ireland continues, to a certain extent, to be treated as part of the EU territory. Before issuing the invoice, it is therefore necessary to determine the destination of the goods and the status of the contractor’s VAT number.

It is also worth checking what the United Kingdom exports, as it is one of Europe’s largest suppliers of services and highly processed products. Its main export goods include machinery and transport equipment, chemicals, fuels and manufactured goods. Business and financial services are also of great importance.

Frequently asked questions about the export of goods outside the EU

Is an invoice sufficient to apply the 0% VAT rate?

No. The invoice documents the sale, but it does not confirm the physical removal of the goods outside the EU. The taxpayer needs an export document, most commonly the IE-599 message.

Does the IE-529 message confirm the completion of the export?

No. IE-529 generally informs about the release of the goods for the export procedure. The confirmation that the goods have left the EU customs territory is the IE-599 message.

Does the absence of IE-599 mean the definitive loss of the 0% rate?

No. The taxpayer may first postpone reporting the transaction and then temporarily apply the domestic rate. Receipt of the confirmation at a later date allows a correction to be made.

Does an exporter need an EORI number?

An entity carrying out activities covered by EU customs regulations generally needs an EORI number. The number is used to identify the business in contacts with customs authorities within the EU.

Does the 0% rate mean an exemption from VAT?

No. An export taxed at the 0% rate remains a taxable transaction, which generally allows the right to deduct VAT on purchases related to it to be retained.