Transport services and VAT exemption in 2026: the PLN 240,000 limit in Poland

Can a Polish transport company use the VAT exemption in 2026? Check the PLN 240,000 limit, VAT-EU registration, domestic transport and fuel costs.

A company providing transport services in Poland may use the small-business VAT exemption in 2026 if it meets the conditions in Article 113 of the Polish VAT Act. Freight transport itself is not among the services that automatically exclude this exemption.

From 1 January 2026, the main threshold is PLN 240,000 of sales. A transport operator must also determine where each service is taxed, whether the customer is a business or a consumer, whether VAT-EU registration is required, and whether giving up input VAT deductions on fuel, leasing and repairs makes economic sense.

Can transport services be exempt from VAT?

Yes. A business established in Poland may generally use the exemption if its sales remain within the threshold in both the previous and current tax year, it does not perform activities listed in Article 113(13), and it correctly identifies which transactions are taxable in Poland.

For a business started during 2026, the PLN 240,000 threshold is calculated proportionally to the period of activity in that year.

The VAT exemption limit in 2026

The exemption threshold increased from PLN 200,000 to PLN 240,000 on 1 January 2026. The exemption ends with the transaction that causes the threshold to be exceeded, not from the following month or year.

VAT itself is not included in the threshold. The Act also lists transactions excluded from the calculation, so bank receipts should not simply be added together without classifying them first.

Example: a carrier has accumulated PLN 238,000 of sales counted towards the limit and accepts a domestic job worth PLN 4,000. The exemption ends for that transaction because it takes the total above PLN 240,000.

Domestic transport under the VAT exemption

For a domestic freight service supplied to a Polish customer, a small carrier may use the exemption while all statutory conditions remain satisfied. The invoice does not show a VAT rate or amount and should state the applicable legal basis, for example Article 113(1) or 113(9), depending on the circumstances.

The trade-off is important: the carrier normally cannot deduct input VAT on purchases connected with exempt sales. For a transport business, this often matters more than it does for a low-cost service company.

Transport for a company in the European Union

For a typical B2B service supplied to a taxpayer in another EU country, the place of taxation is generally the customer's country under Article 28b. The Polish carrier invoices without Polish VAT, while the foreign customer accounts for tax under the rules in its country.

This is neither the Polish small-business exemption nor an intra-Community supply of goods. The carrier supplies a service and does not sell the goods being transported.

Before the first qualifying service, the carrier generally needs VAT-EU registration through form VAT-R. VAT-EU registration does not cancel the domestic VAT exemption, but the relevant services must be reported in VAT-EU recapitulative statements.

Consumer transport requires a separate analysis

Article 28b cannot automatically be used when the customer is not a taxpayer. Freight transport for consumers is subject to special place-of-supply rules that may depend on the route and whether the journey runs between EU countries.

Before invoicing, establish the customer's status, the start and end points, the countries crossed, whether the service qualifies as international transport, and who must account for tax in the relevant country.

VAT exemption and a 0% rate are not the same

A small-business exemption means no output VAT and, generally, no right to deduct input VAT.
A 0% VAT rate is a tax rate available only when specific statutory and documentary requirements are met; an active VAT taxpayer can retain the right to deduct input VAT.
A service outside the scope of Polish VAT may instead be taxed in the customer's country, as in a typical Article 28b B2B case.

Crossing a border alone is not enough to put 0% VAT on an invoice.

Is the VAT exemption profitable for a transport company?

The exemption simplifies domestic settlements but is not always financially attractive. Transport companies often incur substantial VAT-bearing costs: fuel, vehicle leasing or purchase, tyres and repairs, equipment, telecommunications, and some road or parking charges.

An exempt business cannot recover Polish input VAT on purchases connected with exempt sales. When customers are mainly active VAT taxpayers, output VAT is usually neutral for them and the carrier may benefit more from input deductions. When customers are mainly consumers, exemption may improve the gross price.

The decision should be based on several months of real invoices: compare the VAT not charged to customers with the VAT that cannot be recovered from purchases.

Quick checklist before choosing the exemption

Which sales are taxable in Poland and count towards the threshold?
Is the PLN 240,000 limit likely to be exceeded during the year?
Are customers businesses or consumers?
Does the company supply services to taxpayers in other EU countries?
How much Polish VAT is paid on fuel, leasing and repairs?
Do the documents support the intended treatment of international transport?

Oxyok's accounting for transport and forwarding companies brings domestic sales, VAT-EU, fuel, leasing and fleet documents into one process.

Frequently asked questions

Does PKD 49.41.Z exclude the VAT exemption?

No. The Polish business activity code for road freight transport does not itself exclude the exemption. The actual activities and all Article 113 conditions still need to be checked.

Does VAT-EU registration mean becoming an active VAT taxpayer?

No. An exempt taxpayer may register for VAT-EU and continue to use the domestic exemption.

Can an exempt company deduct VAT on fuel?

As a rule, it cannot deduct input VAT on purchases connected with exempt sales. The gross amount may still be a deductible income-tax cost subject to the rules for the vehicle concerned.

Does transport to Germany always carry 0% VAT?

No. The treatment depends on the customer, place of supply, route and documents. A typical B2B service for a German taxpayer often follows Article 28b and reverse charge rather than the Polish 0% rate.

Sources

Need to calculate VAT for your transport company?

Oxyok provides accounting for transport and forwarding companies from PLN 49 plus VAT per month, covering domestic transport, EU customers, fuel, leasing and other company documents.

See the transport accounting service or email [email protected].

This material is general information. VAT treatment depends on the customer, route, documents and exact service model.