Poland: VAT guidelines for deposit-refund system

Rules for settling transactions related to the deposit-refund system under the VAT law

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September 9, 2025

The Polish Ministry of Finance on September 1, 2025, published tax guidelines concerning the rules for settling transactions related to the deposit-refund system under the value added tax (VAT) law.

The guidelines aim to clarify the practical application of VAT provisions for taxpayers and remitters involved in the deposit-refund system. A key feature of the new VAT law solutions is the removal of VAT obligations from taxpayers who are not introducers of products or representative entities in beverage packaging. This change transfers VAT obligations to designated entities, thereby simplifying tax settlement within the deposit system.

The guidelines cover topics such as the subject and basis of VAT taxation in the deposit system, the timing of settlement of unreturned deposits for VAT purposes, excess packaging or packaging waste returned to the deposit system, the role of the representative entity as a VAT remitter, records, and the right to deduct.

Read a September 2025 report prepared by the KPMG member firm in Poland

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