Invoicing a client abroad from Poland: reverse charge, "np" and currencies

When you sell a service to a business abroad, you usually charge no Polish VAT: the service is taxed in the client’s country. What changes is the paperwork. An EU business client means reverse charge wording, a VAT-UE registration and a monthly summary; a client outside the EU means an invoice marked “not taxed in Poland”.

Either way, the invoice goes through KSeF, Poland’s national e-invoicing system, and you can issue it in euros or dollars. This guide covers services sold to businesses (B2B), which is what most freelancers sell: software, design, marketing, translation, consulting. Goods, and sales to private individuals, follow other rules.

Why there is no Polish VAT on the invoice

For a service sold to a business, the place of supply (where the sale is taxed) is where the client has its seat (VAT Act art. 28b). A German company buying your programming work is taxed in Germany, a US company in the US. Poland does not tax the sale, so you charge no Polish VAT.

A few services have their own place-of-supply rules, such as services linked to property, passenger transport, event admission, restaurants and short-term car hire. If your work is one of these, ask your accountant before you invoice.

Two words to keep apart:

• Reverse charge (odwrotne obciążenie): the client pays the VAT in its own country. This is the EU B2B case.
• “np” (nie podlega, not subject to Polish VAT): a marker many invoicing tools, and KSeF, use for sales taxed outside Poland.

Neither is “0%”. The 0% rate is for exports of goods, intra-EU supplies of goods and international transport.

A client in the EU: reverse charge and VAT-UE

When your client is a VAT-registered business in another EU country, you need three things.

1. A VAT-UE registration, before the first such service. This is a separate EU VAT status that puts PL in front of your NIP (the Polish tax number). It is required even if you are VAT-exempt (VAT Act art. 97 ust. 3 pkt 2). You register on the VAT-R form (the VAT registration form), part C.3, and it costs 0 PLN. It does not make you an active VAT payer and does not end your exemption. If you also buy ads or software from abroad, it covers that too; see VAT-UE for Google, Adobe and AWS.

2. The right invoice. Beyond the usual data, it must show:

• the words “odwrotne obciążenie” (reverse charge), required by art. 106e ust. 1 pkt 18;
• your NIP with the PL prefix;
• the client’s EU VAT number, with its country code (for example DE);
• the net amount only: the VAT rate and VAT amount may be left out (art. 106e ust. 5).

3. The VAT-UE summary return (informacja podsumowująca, form VAT-UE). You file it electronically for every month in which you provided such services, by the 25th of the following month (art. 100). There is nothing to pay; it lists your EU clients’ VAT numbers and the amounts. Services that are exempt or 0% in the client’s country are left out of it, so ask your accountant if yours might be one of them.

Tip: check the client’s VAT number in VIES, the EU’s free VAT number check, and save the result with the invoice. If the number does not check out, ask the client before you invoice.

A client outside the EU: the “np” invoice

For a business client in the UK, the US, Switzerland, Ukraine or anywhere else outside the EU, the service is taxed outside Poland too. There is no VAT-UE registration and no VAT-UE summary for it.

The invoice may leave out the client’s tax number and the VAT rate and amount (art. 106e ust. 5 pkt 2). In KSeF’s invoice format, FA(3), the rate field for these sales is “np I”: “not subject to tax, supplies outside Poland”. EU B2B services use “np II” instead, together with the reverse charge flag.

The wording on a non-EU invoice is less settled. Many businesses write “not subject to Polish VAT” or “np”. If the client’s country makes the client pay its own VAT on your service, the reverse charge wording of art. 106e ust. 1 pkt 18 may apply as well. Ask your accountant, or KIS (Krajowa Informacja Skarbowa, the tax office’s helpline), if you want certainty.

EU and non-EU clients side by side

If you are VAT-exempt

Being under the 240,000 PLN limit changes less than people think.

• You must issue the invoice. An exempt business normally invoices only when asked, but a sale taxed in another EU country (where the client pays the VAT) or outside the EU must always be invoiced (art. 106a pkt 2, art. 106b ust. 1 pkt 1).
• Do not mark it “zw” (exempt). It is not an exempt sale, it is a sale outside Poland.
• You still file the VAT-UE summary for EU clients. You file no JPK_V7 for these sales, because exempt businesses do not file VAT returns (art. 99 ust. 7).
• The limit: it counts sales on Polish territory (art. 2 pkt 22). B2B services taxed abroad are therefore generally left out of the 240,000 PLN. This reading comes from Polish tax guides, not from the ministry, so check with your accountant if you are close to the limit. More in the VAT exemption limit.

An active VAT payer reports the same sales in the VAT return, JPK_V7M (or JPK_V7K if you file quarterly): field K_11 for all services supplied outside Poland, and K_12 for the EU reverse charge services, which are counted in K_11 as well.

Does it go through KSeF?

Yes. Invoices to foreign businesses are B2B invoices, so they are issued in KSeF like any other. Your client cannot log in to KSeF, so you send them the PDF version with its QR code by email. The Ministry’s KSeF FAQ says the PDF may be in English or bilingual, as long as it matches the XML file. New to KSeF? Start with what KSeF is.

Penalties for skipping KSeF are enacted from 1 January 2027. A Ministry of Finance draft published on 23 September 2026 would move them to 1 January 2028, but it is not law yet. The obligation itself does not move.

For foreigners: a euro invoice to a large client can pass 10,000 PLN gross on its own. From that invoice onwards, you are in KSeF for the rest of 2026 and beyond.

Currencies: euros on the invoice, złoty in the books

You can invoice in EUR, USD or any other currency; KSeF has a field for it. If an invoice showed VAT, the VAT amount would have to be in PLN (art. 106e ust. 11), but reverse charge and “np” invoices show none, so there is nothing to convert on the invoice itself.

Your records are still in złoty, and two conversions apply:

• VAT (VAT-UE summary, JPK_V7M): the average rate of the NBP (Narodowy Bank Polski, the central bank) from the last business day before the tax point, or, if you prefer, the European Central Bank rate (art. 31a). If you invoice before the work is done, use the last business day before the invoice date instead. For a service, the tax point is when it is done; for a monthly retainer, the end of each billing period (art. 19a).
• Income tax: the NBP average rate from the last business day before the revenue date (PIT Act art. 11a): the day the service is done, but no later than the invoice or payment date (art. 14 ust. 1c).

Example: you finish a project on Friday 25 September 2026 and invoice 2,000 EUR that day. The last business day before is Thursday 24 September, when the NBP rate was 4.3900 PLN per euro. The sale goes into your records as 8,780.00 PLN.

When the client pays later, the rate that day will differ, which creates exchange differences for income tax. Exchange rates on invoices covers those and whether you need a euro account. Komplet, our free Mac app, files each invoice into its month and shows a foreign amount as ≈ PLN at the NBP rate, so you see the złoty value at a glance.

Deadlines for the coming months

When the 25th falls on a weekend or public holiday, the deadline moves to the next business day.

The invoice itself is due by the 15th of the month after the service, and may be issued up to 60 days before it (art. 106i). For work finished in September 2026, that is Thursday 15 October 2026.

What to do next

1. Check whether your client is a business, and in the EU or outside it.
2. EU client: file VAT-R with part C.3 for VAT-UE before the first such service, and check the client’s number in VIES.
3. Set up your invoice template: reverse charge wording or “np”, your PL NIP, the client’s VAT number, the currency.
4. Issue the invoice in KSeF (or as a PDF while you stay under 10,000 PLN a month until 31 December 2026), and email the client the PDF with its QR code.
5. File the VAT-UE summary by the 25th for every month with EU clients.
6. Give your accountant every invoice with its currency and date, so the PLN conversions can be done. What to send your accountant has the full monthly list.