Registration for VAT should be done before the date of performing the first taxable activity (local supply of goods, provision of service, export of goods, import of goods, intra-Community acquisition of goods, intra-Community supply of goods).

Is it possible to register for VAT retroactively in Poland?

Violation of the above obligation are quite frequent, especially when it comes to international entities expanding their business on the Polish market. The reasons behind are i.a. lack of knowledge of Polish tax regulations, business matters (invoicing deadlines), incorrect classification of a movable supply in the supply chain.

Self-retroactive registration, although not regulated in Polish provisions, is possible and free of penalty if fixed on the taxpayer’s initiative with proper documentation (except of interest on VAT late payment if applicable).  If a tax office approaches a taxpayer to register for VAT, such situation may be connected with VAT sanctions and fiscal code penalties for representatives of the taxpayer.

White List issue

Although tax offices accept retroactive registration, the entry date in the register of taxpayers (the so-called White List) is made on the date the tax office receives and examines registration documents. That may generate some confusion and misunderstanding from the vendors’ / the customers’ side, however in such cases – we are open to help You and explain the issue to the , as the date of the first taxable activity is not revealed in the public records.

What documents are needed to retroactively register for VAT

The process of gathering necessary documentation and data to go thorough VAT registration process in Poland generally does not differentiate ongoing registration and the retroactive one.

However, our developed practice shows it is highly recommended to submit additionally:

  • voluntary disclosure signed by taxpayer’s representative,
  • cover letter to explain the situation in a clear and friendly way,
  • request to open past settlement periods.