Polish landscaping works treated as one service subject to 8 percent VAT

Summary

• Vegetation removal, surface and subsurface mulching, biomass handling, land restoration and site tidying performed for one agreed price were treated as a single comprehensive landscaping service. The published analysis classifies the overall supply under PKWiU 81.30 and applies the Polish 8 percent VAT rate. [edgp.gazetaprawna.pl]
• Because the service related to land situated in Poland, Poland was treated as the place of supply. The supporting activities were not analysed as separate services because the customer sought one integrated result: the rapid and effective rehabilitation and organisation of the area surrounding its premises. [edgp.gazetaprawna.pl]
• Suppliers should ensure that contracts, quotations, completion records, PKWiU classifications and KSeF invoices consistently describe the principal landscaping outcome. Separate treatment may be necessary where waste removal, construction, demolition or other activities constitute independent supplies rather than ancillary components of a landscaping project. [edgp.gazetaprawna.pl]

Article

A Polish analysis has examined the VAT treatment of a combined project involving vegetation removal, mulching, biomass handling, land restoration and general tidying around a company’s premises.

The contractor performed the work between 27 May and 11 September 2026. The parties agreed one net price of PLN 100,000, determined by reference to the surface area and the density and type of vegetation. A structured invoice was issued through KSeF on 18 September 2026 for PLN 108,000, including PLN 8,000 of VAT, and payment was received on 25 September 2026. [edgp.gazetaprawna.pl]

The principal VAT issue was whether the individual activities should be classified and taxed separately or treated as components of one comprehensive service. The customer’s objective was not to purchase isolated tree removal, mulching, biomass disposal and surface levelling services. It sought one integrated commercial result consisting of the efficient restoration and organisation of the green area surrounding its headquarters.

On that basis, the activities were treated as a single landscaping service classified under PKWiU 81.30 and taxable at the 8 percent VAT rate. Removal and transport of biomass were regarded as ancillary to the principal landscaping outcome rather than independent waste-management services. [edgp.gazetaprawna.pl]

The analysis also treated Poland as the place of supply because the services were directly connected with immovable property located in Poland. This conclusion is relevant for cross-border transactions because services sufficiently connected to specific land or buildings are generally taxed where that property is situated.

The classification depends heavily on the facts. The conclusion may differ if vegetation removal, waste transport, demolition, construction or remediation is separately ordered, separately priced or commercially valuable in its own right. Similarly, work involving the construction, reconstruction or renovation of structures may fall outside the landscaping classification described in the article.

Suppliers should ensure that the contract, work order, completion document and KSeF invoice describe a consistent principal service. The agreed scope, pricing structure and customer objective should support the intended comprehensive-supply analysis. Businesses should also retain evidence supporting the PKWiU classification and the application of the reduced rate.

For purchasers, the invoice description should be reviewed against the work actually completed. An overly broad “landscaping” label should not be accepted automatically if the project contains substantial construction, demolition or independent waste-disposal elements.

Source Links

• Gazeta Prawna: VAT and PIT treatment of commercial landscaping works

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