Selling abroad increasingly does not stop at the border of the EU. Sole proprietorships trading in goods reach customers in the United Kingdom, the United States, Switzerland or Asian countries, and such a transaction is settled quite differently from an intra-Community supply of goods or a consumer sale under the OSS procedure. Exporting goods has its own definition, its own conditions for applying the 0% VAT rate, and its own documentation — and a mistake in this settlement usually means paying the VAT out of the seller's own pocket.
What counts as an export of goods and who may carry it out
Under Article 2(8) of the VAT Act, the export of goods is the removal of goods from the territory of Poland to a destination outside the territory of the European Union, confirmed by a customs office, carried out by the supplier or on the supplier's behalf, or by a buyer established outside Poland or on that buyer's behalf. Goods may be exported both by an active VAT payer and by an entrepreneur using the subjective VAT exemption — it is one of the taxable activities listed in the Act alongside a domestic supply of goods and an intra-Community supply of goods. An important caveat: the value of export sales counts toward the threshold for the subjective exemption, which since 1 January 2026 stands at PLN 240,000 of net sales value per year. A VAT-exempt business that sells goods outside the EU on a significant scale may therefore cross that threshold sooner than domestic sales alone would suggest.
Direct export versus indirect export
The distinction depends solely on who arranges the transport of the goods beyond the Union's border. Direct export occurs when the seller arranges the transport — the customs documents are then issued in the seller's name. Indirect export occurs when the buyer, or an entity acting on the buyer's instructions, arranges the transport — for instance by collecting the goods in Poland and taking them abroad itself — with the buyer named as the declarant on the customs documents. The distinction matters in practice because it determines who has direct access to the document confirming the export and who must ensure it reaches the seller so the 0% rate can be applied. With an indirect export, it is worth agreeing in advance with the foreign counterparty that a copy of the customs message will be forwarded — without it, the seller may have no grounds for applying the preferential rate.
The condition for the 0% rate — the document confirming export
The preferential 0% VAT rate, available only to active VAT payers, applies on condition that, before the deadline for filing the JPK_V7 for the given settlement period, the taxpayer receives a document confirming that the goods left the territory of the European Union. In practice this is the electronic IE-599 message, generated in the system handling export declarations once the export procedure is closed — it is preceded by a customs declaration (the IE-515 message). A paper SAD document confirmed by the competent customs office is also acceptable. If the document is missing within the deadline applicable to the given period, the sale is not yet shown at the 0% rate — it is carried over to the settlement for the following period, provided the document arrives before the deadline for filing the JPK_V7 for that following period. If the document is still missing at that point, the rate applicable to a domestic sale must be applied, with a correction and recovery of the difference possible only once the proof of export is actually received.
Advance payments toward an export
The 0% rate can also be applied to an advance payment received before the goods are exported, provided the export takes place within six months of the end of the month in which the taxpayer received the payment, and the document confirming export arrives within the same period. A longer wait for the export does not automatically rule out the 0% rate if it results from the specific nature of that particular supply, as confirmed by the terms of the contract concluded — for example, custom-made production with a long manufacturing cycle. This cannot, however, be an arbitrary decision by the parties made purely for accounting convenience — the extended export deadline must arise from the genuine nature of the transaction.
KSeF, the export invoice and settlement for PIT purposes
The mandatory National e-Invoice System (KSeF) has, since 2026, also covered export sales, in line with the schedule for entry into force applicable to particular groups of taxpayers. A foreign counterparty without a Polish tax number cannot, however, log in to the system, so the invoice must be delivered outside KSeF — usually as a PDF file with a QR code, or as a visualisation sent by email — while the seller still issues the invoice within KSeF. The buyer is identified in the invoice structure by an identification number (a VAT-EU number for counterparties from the Union, a foreign tax number for others) together with a country code. For income tax purposes, revenue from an export is recognised on general principles — on the day the goods are handed over or the invoice is issued, whichever comes first — and amounts expressed in foreign currency are converted at the average exchange rate of the National Bank of Poland from the day preceding the day the revenue arises.