VAT Recovery on Imports Remains Possible Even Without Ownership of Goods

A recurring issue in international supply chains concerns imports where the importer is not the legal owner of the goods. According to the commentary cited from Rzeczpospolita, the absence of ownership does not automatically eliminate the possibility of recovering import VAT.

The issue is particularly relevant in contract manufacturing, tolling arrangements, logistics structures and other cross-border business models where multiple parties participate in a transaction while ownership remains with only one entity. In such cases, the decisive factor is often the economic role of the importer and the relationship between the imported goods and the taxable activities carried out by that importer.

For multinational groups and indirect tax teams, the development serves as a reminder that import VAT recovery should be assessed based on the totality of facts, rather than on ownership alone. Businesses should ensure that import documentation, contractual arrangements and VAT positions remain aligned and well supported.