An online shop run as a sole proprietorship rarely stops at the border. A few orders a month from Germany, the Czech Republic or France are enough to raise the question of which country's VAT should be added to the price. The answer does not depend on where the business is registered, but on how much you sell to consumers in other EU member states — and on a single threshold that is easy to overlook.
When a sale to an EU consumer stops being a domestic sale
The key concept is intra-Community distance selling of goods, abbreviated in Polish as WSTO. It covers a supply in which goods are dispatched or transported by the seller, or on the seller's behalf, from one member state to a buyer in another member state, where that buyer is a consumer or another entity that does not account for an intra-Community acquisition. A typical example is a parcel sent from a Polish warehouse to a customer in Germany who is buying privately.
Similar logic applies to some services supplied to consumers — above all telecommunications, broadcasting and electronic services, for which the place of taxation is the customer's country. It is worth distinguishing these transactions from business sales straight away. In B2B trade with a counterparty using an EU VAT number, the tax is usually accounted for by the buyer, and the seller reports an intra-Community supply or a service under the reverse charge. In a sale to a consumer there is nobody to shift the obligation to — it stays with the seller.
The threshold of EUR 10,000, or PLN 42,000
The method of settlement depends on a single threshold: EUR 10,000, which for Polish entrepreneurs means PLN 42,000. This is the net value of all distance sales of goods and of the services mentioned above to consumers from all EU countries combined, not a separate limit for each country. The threshold must not have been exceeded either in the current or in the previous tax year.
As long as you stay within the limit, you settle these sales as domestic ones — with the Polish VAT rate and in the standard JPK_V7 filing. Once the threshold is exceeded, the place of taxation moves to the country where the consumer lives, and from that moment you apply the rates in force in the buyer's country. The change takes effect by operation of law, without any decision by a tax office.
Below the threshold you may also voluntarily opt for taxation in the country of consumption, for instance where the local rate is lower than the Polish one. Notification of that choice is made on form VAT-29, by the 10th day of the month following the month in which the choice was made. The decision cannot be reversed from one month to the next, however — it is binding for at least two consecutive years.
Three routes to settlement, and why OSS usually wins
Where a transaction is taxable in the buyer's country, two routes are available. The first is VAT registration in every country in which you have customers, together with local returns filed there. If you sell to several countries, that means several registrations, several tax calendars and usually the cost of a local representative. The second is the EU One Stop Shop scheme, known as VAT OSS.
OSS does not change the amount of tax — the rates remain those of the consumer's country. What it changes is the way the tax is settled: you report all foreign consumer sales in a single return filed in Poland and make one payment, and the Polish administration transfers the funds to the relevant countries. For a sole trader with scattered sales, that is usually the difference between one and a dozen reporting obligations per quarter.
Registration: the VIU-R notification and one tax office for the whole EU
You join the EU scheme using form VIU-R, filed electronically with the Head of the Second Tax Office Warszawa-Śródmieście. The notification is submitted through the e-Deklaracje system and, since February 2025, also through the e-Urząd Skarbowy electronic tax office. The condition for using OSS in Poland is being registered for VAT in the country — the status of a VAT-exempt taxpayer is sufficient, active registration is not required.
This matters for smaller businesses. Sales settled through OSS are not taxable in Poland, so they do not count towards the domestic exemption limit, which in 2026 stands at PLN 240,000. You can therefore benefit from the VAT exemption on domestic sales and at the same time account for foreign sales under the EU scheme.
The VIU-DO return, payment in euro and ten years of records
Settlement under the EU scheme is quarterly. The VIU-DO return is filed electronically by the end of the month following the close of the quarter, that is by 30 April, 31 July, 31 October and 31 January. The deadline does not move to a working day if it falls on a weekend, and the return must be filed even if there were no sales covered by the scheme in a given quarter.
Once the return is filed, the system assigns a unique reference number (UNR) in a format similar to PL/PLXXXXXXXXXX/Q1.2026. The tax is paid in euro to the designated account of the Second Tax Office Warszawa-Śródmieście, and the payment title must contain the UNR alone — with no additions. Transfers described differently may be rejected and returned. A payment made to the ordinary tax micro-account will not be forwarded to the countries of consumption.
On top of this comes the obligation to keep separate, exclusively electronic records of the transactions covered by the scheme. They must be retained for ten years counted from the end of the year in which the supply of goods or services took place, and made available to the authorities on request in a form allowing the data to be found quickly.
What OSS does not cover
The most common misunderstanding concerns costs. The VIU-DO return shows output tax only — there is no place in it for input VAT on purchases. Domestic purchases are deducted under the usual rules in the JPK_V7 filing, while VAT paid in another member state is recovered through the separate VAT-REF refund procedure. The application is submitted via the Polish tax office by 30 September of the year following the year to which it relates.
Corrections are a separate matter. As a rule they are made in subsequent returns filed in the state of identification, and since 1 July 2023, in specific situations — for example after deregistering from the scheme or after changing the state of identification — a correction may be submitted directly to Poland as the country of consumption. It is worth knowing this route before the first return of goods from several quarters back arrives.