Invoice to an EU business from Poland 2026: np II and reverse charge

A Polish company invoices a service for a business in another EU country without Polish VAT, because the place of supply is the buyer's country and the buyer accounts for the tax (art. 28b ust. 1 of the VAT Act). On the invoice you enter the rate "np II", the buyer's EU VAT number and the words "odwrotne obciążenie" (reverse charge, art. 106e ust. 1 pkt 18), and you report the service in JPK_V7 and in the VAT-UE summary by the 25th of the following month (art. 100 ust. 1 pkt 4 and ust. 3).

Law as of 11 November 2026.

The VAT Act applies in the consolidated text Dz.U. 2026 poz. 1263. The amendments Dz.U. 2026 poz. 1270 and 1446 do not change the rules described here. Below: when a service carries no Polish VAT, what goes on the invoice and into KSeF, when to issue it, how to report it in JPK_V7 and VAT-UE, and what applies to goods.

When a service for an EU business carries no Polish VAT

The rule in art. 28b ust. 1 of the VAT Act applies when three conditions are met:

• the buyer is a taxable person, meaning it runs a business or is a legal person identified for VAT (art. 28a),
• it is established in another EU country, or the service is for its fixed establishment in another country (art. 28b ust. 1 and 2),
• the service is not for private use of the buyer, its staff or its shareholders (art. 28b ust. 4).

Typical examples are software development, consulting, marketing, design, translation and research. Before the first invoice, ask the client for its EU VAT number with the country code, check it in the EU's VIES search and keep the result with the contract.

Some services have their own place of supply and art. 28b does not cover them:

A private client in the EU is a different case. For services to consumers the rule is Polish VAT (art. 28c ust. 1), with exceptions for electronic services among others (art. 28k).

What the invoice to an EU business must contain

Do not enter "zw" (exempt) or "0%". The exemption and the 0% rate apply to sales in Poland or to supplies of goods, while an art. 28b service is not subject to Polish VAT at all. You may issue the invoice in euro. With no Polish VAT there is no tax amount to convert into złoty on the invoice.

The invoice to an EU business in KSeF

The company issues the invoice to a foreign business in KSeF, just like a domestic one (art. 106ga ust. 1 of the VAT Act). The EU buyer has no access to the system, so you hand the invoice over in an agreed way, usually as a PDF with a QR code that leads to the invoice in KSeF (art. 106gb ust. 4 pkt 1 and 2 and ust. 5). The receipt date is the day the buyer actually receives it (art. 106na ust. 4). Until the end of 2026, a business whose invoices total no more than 10,000 zł including VAT a month may still invoice outside KSeF (art. 145m ust. 1 of the VAT Act).

In the FA(3) structure such an invoice carries three markers:

• P_12 = "np II" on every line with an art. 100 ust. 1 pkt 4 service,
• P_13_9: the total value of these services,
• P_18 = 1: the "odwrotne obciążenie" annotation.

The rate "np I" is for other transactions outside Poland, for example services connected with real estate abroad. You can prepare an FA(3) file with the np II rate in złoty in the free KSeF invoice generator. How the KSeF duty works in a company is explained in KSeF for a sp. z o.o..

Invoice deadline and tax point

You issue the invoice by the 15th of the month after the month in which you performed the service (art. 106i ust. 1 of the VAT Act). An advance from an EU client is invoiced by the 15th of the month after the month you received it (art. 106i ust. 2). You cannot issue the invoice earlier than 60 days before the service or the payment (art. 106i ust. 7).

For JPK_V7 and VAT-UE, the moment of performance counts, not the invoice date (art. 100 ust. 11 with art. 19a ust. 1–3 and 8):

You convert the euro amount into złoty at the NBP average rate of the last working day before the day of performance (art. 31a ust. 1). The details are in foreign currency invoice in Poland, and the rate is in the NBP rate for an invoice tool.

How to report the service in JPK_V7 and VAT-UE step by step

1. Register the company as an EU VAT payer (podatnik VAT UE) before the first such service, in the VAT-R form. This also applies to a VAT-exempt company (art. 97 ust. 3 pkt 2 of the VAT Act). From registration you use your number with the prefix PL (art. 97 ust. 10).
2. Check the buyer's number in VIES and save the result.
3. Issue the invoice in KSeF with the np II rate and the "odwrotne obciążenie" annotation, and send the buyer the PDF with the QR code.
4. Report the service in JPK_V7 for the month of performance. An active VAT payer records it as a supply of services outside Poland, separately as art. 100 ust. 1 pkt 4 services, with no output VAT (§ 4 pkt 1 lit. b and § 10 ust. 1 pkt 3 of the regulation, Dz.U. 2019 poz. 1988). This amount is not part of the total tax base (§ 4 pkt 2).
5. File the VAT-UE summary (informacja podsumowująca) electronically by the 25th of the following month (art. 100 ust. 3). For each buyer you give its EU VAT number with the country code and the total value of the services (art. 100 ust. 8 pkt 2 and 4).
6. Fix errors at once. If VAT-UE contains an error, you file a correction without delay (art. 101).

You deduct VAT on the costs of this service

No Polish VAT on the invoice does not take away the company's deduction. An active VAT payer deducts VAT on purchases linked to services outside Poland if it could deduct it for the same service in Poland and has documents showing the link (art. 86 ust. 8 pkt 1 of the VAT Act). Art. 28b services also do not count towards the 240,000 zł exemption limit, because they are not sales in Poland (art. 2 pkt 22, art. 113 ust. 1).

Example: an 8,000 EUR IT service for a German company

A Polish sp. z o.o., an active VAT and EU VAT payer, completes a system rollout for a German GmbH on 30 October 2026 and issues an invoice for 8,000 EUR on the same day.

Had the company charged 23% Polish VAT, the invoice would show 8,086.98 zł of tax (35,160.80 zł × 23%) that is not due in Poland, and it would need a correction.

Goods for an EU business: intra-Community supply at 0%

When it ships goods to a business in another EU country, the company applies the 0% rate as an intra-Community supply of goods (WDT, wewnątrzwspólnotowa dostawa towarów) if it meets three conditions (art. 42 ust. 1 of the VAT Act):

1. The buyer gave a valid EU VAT number with the country code.
2. Before the JPK_V7 deadline for the period, the company holds evidence that the goods left Poland and reached the buyer, for example transport documents (art. 42 ust. 3).
3. The company is registered as an EU VAT payer and reports the supply correctly in VAT-UE (art. 42 ust. 1 pkt 3 and ust. 1a).

In KSeF the rate is "0 WDT" and the total goes in field P_13_6_2. The tax point is the invoice date, at the latest the 15th of the month after the supply (art. 20 ust. 1). On monthly filing without evidence, you leave the supply out for that month. If you still have none by the JPK deadline for the period after the next one, you report it in that JPK at the domestic rate. Evidence received later lets you return to 0% by a correction (art. 42 ust. 12 pkt 2 and ust. 12a).

The most common mistakes

You buy a service from an EU business

In the other direction your company accounts for the tax as an import of services (art. 17 ust. 1 pkt 4 of the VAT Act), even when it is VAT-exempt. EU VAT registration is then needed before the first purchase (art. 97 ust. 3 pkt 1). We explain this in VAT registration in Poland.

How Norman helps

Norman sends the company's invoices to KSeF, pulls purchase invoices from it and matches bank payments to documents. In Max for 119 zł a month, net, Norman keeps the VAT register and prepares the VAT-UE summary and JPK_V7 for your approval, so a service for an EU client lands in both reports for the right month. You can also prepare an np II invoice for free and without signing up in the KSeF invoice generator, and read about Norman on the home page.

Frequently asked questions

Does an invoice to an EU business need the words "odwrotne obciążenie"?

Yes. When the buyer accounts for the VAT, the invoice must contain the words "odwrotne obciążenie" (art. 106e ust. 1 pkt 18 of the VAT Act). In KSeF you mark it with the value 1 in field P_18.

What does np II mean on an invoice?

It is a service for a business in another EU country that is not subject to VAT in Poland and goes into the VAT-UE summary (art. 100 ust. 1 pkt 4 of the VAT Act). The rate "np I" covers the other transactions outside Poland.

Do I issue an invoice to a German company in KSeF?

Yes. The company issues it in KSeF and hands it to the buyer in an agreed way, for example as a PDF with a QR code (art. 106gb ust. 4 and 5 of the VAT Act).

When is VAT-UE due for services to EU businesses?

By the 25th of the month after the month in which you performed the service or received an advance, electronically only (art. 100 ust. 3 of the VAT Act). For October 2026 the deadline is 25 November 2026.

Can a VAT-exempt company sell services to EU businesses?

Yes, but before the first service it registers as an EU VAT payer and files VAT-UE (art. 97 ust. 3 pkt 2 of the VAT Act). These services do not count towards the 240,000 zł limit, because they are not sales in Poland.