Poland: Draft legislation making e-invoicing mandatory effective 1 January 2024

Mandatory e-invoicing would cover all the activities subject to domestic VAT.

Mandatory e-invoicing would cover all the activities subject to domestic VAT.

The government on 1 December 2022 published draft legislation amending the value added tax (VAT) law to make e-invoicing mandatory effective 1 January 2024.

Mandatory e-invoicing would cover all the activities subject to domestic VAT, including:

  • Domestic supplies of goods and provisions of services between companies (B2B)
  • Supplies and provisions to public authorities (B2G)
  • Supplies and provisions to consumers (B2C)

The obligation to issue e-invoices via a national e-invoicing system would be imposed on taxpayers performing activities subject to the invoicing obligation under Polish VAT law having their seat or fixed base in the territory of Poland. It would also cover taxpayers under subjective tax exemption (small businesses).

Mandatory e-invoicing would exclude taxpayers applying special schemes, such as the non-union scheme for certain services, the special scheme on occasional international road carriage of passengers, and the special scheme for distance sales of goods imported from third territories or third countries.

It is expected that from 2025 the possibility of issuing invoices using cash registers would cease to be available. Moreover, cash register receipts bearing the buyer’s tax identification number up to PLN 450 would no longer be treated as invoices.

Under the draft legislation, users of e-invoices would enjoy a reduced standard VAT refund period (i.e., 40 instead of 60 days).

The draft legislation is expected to be passed by the Council of Ministers in the first quarter of 2023.

The Ministry of Finance also launched a public consultation on the new e-invoice structure template.

Read a December 2022 report prepared by the KPMG member firm in Poland


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