Google Ads, Adobe or AWS invoices: do you need VAT-UE registration if you're VAT-exempt?

Usually, yes. If you run a Polish business and pay a company abroad for ads or software, such as Google Ads or Adobe, the purchase is an import of services (import usług) and you, not the seller, owe the VAT on it. That is true even if you are VAT-exempt, so you register as a VAT-UE taxpayer before the first purchase and declare the VAT for each month you buy. AWS is the exception: it bills Polish customers with Polish VAT.

Why is a Google or Adobe invoice an “import of services”?

When one business sells a service to another, the service is normally taxed where the buyer is based (VAT Act art. 28b). You are in Poland, so the place of supply is Poland. When the seller has no seat and no fixed establishment in Poland, the law makes you, the buyer, the person who owes the Polish VAT (art. 17 ust. 1 pkt 4). This is often called reverse charge.

That is why these invoices show no VAT, often with a note such as “reverse charge”. The VAT has not disappeared. It has moved to you.

Typical examples:

• advertising: Google Ads, Meta (Facebook and Instagram) ads
• software subscriptions: Adobe, Figma, GitHub
• platform fees, for example Upwork

The seller can be in another EU country or outside the EU; the rule is the same. What matters is that the seller named on the invoice is a company abroad with no Polish establishment involved in the sale, and that you buy as a business.

Watch out: AWS is different. Amazon Web Services EMEA SARL bills accounts located in Poland through its Polish branch, which charges Polish VAT like a local seller. That invoice is an ordinary Polish purchase: no reverse charge and nothing extra to declare. Always look at the seller and the VAT line on the invoice, not at the brand.

Must a VAT-exempt freelancer register for VAT-UE?

Yes. VAT-UE is a separate registration for businesses that buy or sell services across borders. A business that is not an active VAT payer must still be registered as a VAT-UE taxpayer (podatnik VAT UE) before it buys services that count as an import of services (VAT Act art. 97 ust. 3). “Before” means before the first purchase, not after the first invoice arrives.

Registration is simple:

You do not need to become an active VAT payer. VAT-UE does not end your exemption: you keep the 240,000 PLN limit for 2026 and you still do not charge VAT to Polish clients. To see how that limit works, read the VAT exemption limit.

For foreigners: your nationality does not matter, only that your business is Polish. A JDG (a Polish sole trader business) run by a Belgian, a Ukrainian or an American follows exactly the same rule.

Why your NIP needs the PL prefix

Once you are registered, you use your NIP (Polish tax number) with the PL prefix, for example PL1234567890, when you buy these services (art. 97 ust. 10). Enter it in the billing settings of each account, in the “VAT ID” or “tax number” field.

The supplier checks the number in VIES, the EU’s register of VAT numbers. With a valid number, it bills you without VAT and you account for the VAT yourself. Without one, some platforms treat you as a private consumer and add VAT to the invoice themselves. That does not change who legally owes the VAT: a business buyer is still the taxpayer. Platforms behave differently, so if an invoice already shows VAT, ask your accountant how to treat it.

Tip: once the tax office confirms your VAT-UE registration, add the PL number to every supplier account the same day, so the next invoice comes out right.

What do you file each month?

It depends on your VAT status.

VAT-9M is a short VAT return for businesses that owe VAT without being active VAT payers (VAT Act art. 99 ust. 9). The current version is VAT-9M(11), and you can fill it in online on the Ministry of Finance’s forms page. You pay the VAT to your personal tax micro-account by the same day. If the 25th is a Saturday, Sunday or public holiday, the deadline moves to the next working day (Tax Ordinance art. 12 § 5).

Which month a purchase belongs to

The VAT is due when the service is performed (art. 19a). For a subscription or ads billed in periods, that is the end of each billing period (art. 19a ust. 3). If you pay before the service, for example a prepaid top-up, the tax point can be the day of payment (art. 19a ust. 8). When a billing period and a calendar month do not line up, check with your accountant.

Which exchange rate to use

Most of these invoices are in euros or dollars. You convert the net amount to złoty at the NBP (National Bank of Poland) average rate from the last business day before the tax point, or you may choose the European Central Bank (ECB) rate instead (art. 31a). More in exchange rates on invoices.

Example: a VAT-exempt JDG pays Adobe for a billing period from 1 to 30 September 2026: 100 EUR net. The tax point is 30 September, so the rate to use is the NBP rate of 29 September. At an illustrative 4.3900 PLN per euro (the NBP rate on 24 September 2026), the net amount is 439.00 PLN and VAT at 23% is 100.97 PLN. The return rounds both to full złoty (Tax Ordinance art. 63): 439 PLN and 101 PLN, declared on VAT-9M and paid by 26 October 2026.

Does the VAT you pay count as a cost?

It can, depending on how you pay income tax. If you are VAT-exempt and pay tax on the scale or the 19% flat tax, the VAT you pay on an import of services is a tax-deductible cost, because you cannot deduct it as VAT (PIT Act art. 23 ust. 1 pkt 43). On ryczałt (the flat-rate tax on revenue), no costs are deducted, so the 23% is simply an extra cost.

This is one reason some freelancers with many foreign subscriptions become active VAT payers: for them the same VAT is usually neutral. The price is that you then charge VAT to Polish clients and file JPK_V7M every month.

What if you’ve been paying for months without registering?

This is common in the first months of a new business, and it can be put right. Doing it yourself before the tax office asks is much better than waiting.

1. Register for VAT-UE now on VAT-R. Registration works from the day you file it, not backwards.
2. Add your PL number to every foreign supplier account.
3. File a VAT-9M for each past month with a purchase, with the VAT converted at the rate for each tax point.
4. Pay the VAT with late-payment interest (odsetki za zwłokę). Interest runs from the day after each original deadline (Tax Ordinance art. 53); you work it out yourself.
5. Consider a czynny żal (voluntary disclosure). Filing late, or not registering, can be treated as a fiscal offence. You are not punished for it if you notify the tax office before it has documented evidence or starts a check, and pay what you owe by the date it sets (Fiscal Penal Code art. 16). You can send it through e-Urząd Skarbowy.

If there are many months or large amounts, let an accountant do the sums and the letter.

Keep every foreign invoice, including the ones you did nothing with. They arrive by email or sit on each supplier’s billing page, not in KSeF (the national e-invoicing system), which is why they are so easy to miss. Komplet, our free Mac app, reads these PDFs, files each one into the right month and shows an approximate złoty amount next to the euro or dollar figure.

Watch out: suspending your business does not stop this. A foreign subscription that keeps billing while your JDG is suspended is still an import of services and still has to be declared.

When you can leave VAT-UE

If you stop buying services from abroad, and do not sell services to EU businesses either, update VAT-R within 15 days to leave VAT-UE (art. 97 ust. 13). If you do sell services to businesses in other EU countries, you need VAT-UE for that too, and you also file the VAT-UE summary return; see invoicing a client abroad.

What to do next

1. List every foreign supplier you pay: ads, software, cloud, platforms. Note which invoices show no VAT, and who the seller is.
2. If you are VAT-exempt and not yet registered for VAT-UE, file VAT-R with part C.3 ticked before the next purchase.
3. Add PL + your NIP to each supplier account.
4. Each month with a purchase, file VAT-9M and pay by the 25th of the following month.
5. If you missed earlier months, file them now, pay with interest, and consider a czynny żal.
6. Collect the invoices every month and hand them over with the rest; our guide on what to send your accountant has a checklist.