Summary
- Poland’s National Revenue Information Service treated domestic transport, customs-clearance support and temporary warehousing performed under one order as a single complex freight-forwarding service. [taxmachine.pl]
- Because the Turkish business customer had neither its business establishment nor a fixed establishment in Poland, the service was taxable at the customer’s place of establishment under Article 28b(1) of the Polish VAT Act. [taxmachine.pl]
- The Polish supplier retained the right to deduct VAT charged by its Polish subcontractors, subject to the normal requirements for input VAT deduction. [taxmachine.pl]
Extended article
The Director of Poland’s National Revenue Information Service has issued an individual interpretation on the VAT treatment of a package of freight-forwarding and logistics services supplied to a Turkish customer.
The applicant was an active Polish VAT taxpayer providing freight-forwarding services. It did not own vehicles or warehouse facilities but organised the relevant activities using Polish road carriers, a customs agency and a logistics operator. [taxmachine.pl]
Its customer was a Turkish freight forwarder with no establishment or fixed establishment in Poland. The Turkish company handled the international Turkey-Poland transport leg itself and engaged the Polish company to organise the Polish part of the operation. [taxmachine.pl]
Under one order, the Polish company arranged domestic road transport, customs formalities and temporary warehousing. The warehousing activities included unloading, storage for one to three days, completion of the consignment and reloading. No dedicated warehouse area was placed at the exclusive disposal of the Turkish customer. [taxmachine.pl]
The Polish company invoiced the customer once for the combined activities. It had previously treated its recharge of subcontractor costs as subject to 23% Polish VAT.
In interpretation 0114-KDIP1-2.4012.412.2026.1.RM, dated 17 August 2026, the Director accepted that the activities formed one complex freight-forwarding service. The domestic transport, customs support and short-term warehousing were not treated as independent services for determining the place of supply. [taxmachine.pl]
The service was therefore governed by the general B2B rule in Article 28b(1) of the Polish VAT Act. As the Turkish recipient was a taxable person established outside Poland and had no Polish fixed establishment receiving the service, the place of taxation was the recipient’s country of establishment. [taxmachine.pl]
The authority also accepted the Polish company’s right to deduct input VAT charged by its Polish subcontractors, subject to the applicable deduction conditions. [taxmachine.pl]
The interpretation is relevant to freight forwarders and logistics coordinators that purchase several local components but sell an integrated service to a foreign business customer. The contractual and economic relationship between the components is critical. The decision does not mean that every combination of transport, customs and warehousing automatically constitutes one service.
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