Foreign software bills when your Polish JDG is VAT-exempt
A practical checklist for foreign subscriptions: supplier details, reverse charge, VAT-UE and the documents your accountant needs.
You invoice clients without Polish VAT, then buy an overseas software subscription marked “reverse charge”. Your sales exemption does not settle the VAT treatment of that purchase.
Read the supplier details first
Find the legal seller and its country on the invoice, alongside your JDG details and subscription period. The app's brand, billing currency and bank location do not identify the seller reliably. Download the invoice from the billing account; a card notification contains less useful evidence.
Why an exempt business may still owe VAT
For B2B services covered by Article 28b, the general place-of-supply rule follows the customer's establishment, subject to exceptions. A foreign service purchase can therefore create Polish import-of-services duties even for an exempt JDG. Check VAT-UE registration before the first qualifying purchase.
VAT-9M covers specified purchases where the taxpayer does not report them through JPK_V7 or VAT-8. Do not select a return just from an invoice label. VAT charged by the supplier is not, by itself, proof that the treatment is correct.
Send one complete billing example
Give your accountant the invoice, payment confirmation, service period and business purpose. Say whether you supplied your NIP and whether VAT-UE registration is in place. For an annual subscription paid upfront, include the payment date; the PDF date alone may not determine the reporting period.
Agree the return, period, tax amount and process for future bills. Keep the software account password to yourself.
Sources
Contact Oxyok
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