Poland is consulting on VAT refund rule changes for foreign taxpayers to align refund claims with KSeF e-invoicing requirements from 2026. The draft relaxes invoice attachment obligations but requires KSeF invoice identification numbers where available, with different evidence rules for EU and non-EU claimants.
Poland: Consultation on VAT Refunds for Foreign Taxpayers
Public
Poland
Author: Ema Stamenković
Category:
Fiscal subject related
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384
Content accuracy validation date:
21.05.2026
Content accuracy validation time:
08:13h
Poland has launched a public consultation (opened April 15, 2026, by the Ministry of Finance and Economy) on proposed changes to VAT refund rules for foreign taxpayers (both EU and non-EU claimants), aligning the refund process with the mandatory National e-Invoice System (KSeF).
The draft regulation updates the existing VAT Refund Regulation to reflect that invoices in Poland will generally be issued via KSeF. Under KSeF, invoices may be made available in different formats; the draft clarifies how foreign taxpayers should evidence VAT refund claims.
The general obligation to attach invoices to refund applications will be relaxed. For invoices issued via KSeF, claimants must provide KSeF invoice identification numbers with their application where available. If such numbers are not provided: EU claimants must submit copies (reproductions) of received invoices electronically; non-EU claimants must attach paper invoices and send or make available electronic invoices to Polish tax authorities at submission (e.g., by email).
Transitional provisions: existing rules apply to refund applications for periods before January 1, 2026 (invoices issued in 2025). Amended rules apply to applications for periods starting from January 1, 2026 (invoices issued in 2026), provided applications are submitted after the new regulation enters into force. For quarterly applications submitted before the regulation enters into force, current rules continue to apply even if the period relates to 2026.
The draft regulation is expected to enter into force the day following publication. Businesses should monitor developments and assess the impact on their VAT refund processes, especially regarding KSeF invoice identification requirements.
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