The subject of sales can be both goods and intangible assets such as licenses. To determine place of taxation for the sales of licenses to non-EU countries it is crucial to check if the sales is done to a private individual (B2C) or to business (B2B).
In case of B2B applicable would be art. 28b of the Polish VAT Act. According to this provision, the place of supply of services in such case is the place where the taxpayer who is the recipient of the service has its registered office. Consequently, these services are not subject to taxation in Poland, but on the basis of a reverse charge – in the country of the recipient.
Source Intertax
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