VAT revolution? 7 changes taxpayers should pay attention to

The amendment to the Polish VAT Act of 4 September 2026, published in the Journal of Laws of 2026, item 1270, introduces a broad package of changes to VAT regulations.

Not all of the new rules will be equally important for businesses. However, some of them may have a significant impact on daily VAT settlements, accounting processes, cooperation with contractors and tax risk management.

Below we present seven areas that deserve particular attention.

1. New VAT warehouse regime

One of the key changes is the introduction of a VAT warehouse regime.

For certain transactions involving goods, it will be possible to apply a 0% VAT rate and defer the economic burden of VAT until the relevant procedure is completed.

This mechanism may be particularly relevant from a cash flow perspective and should be analysed by businesses operating within more complex supply chains.

2. Joint and several liability extended to services

One of the most significant changes concerns the extension of joint and several liability to certain services.

The new rules may create additional risks for purchasers of, among others, IT, accounting, advisory, advertising and administrative services.

In practice, this increases the importance of contractor verification procedures. The change may be relevant not only to ongoing relationships with service providers, but also to tax due diligence processes and M&A transactions.

3. Changes to mandatory split payment

The amendment also affects the mandatory split payment mechanism.

Changes to the classification of goods listed in Appendix 15 to the VAT Act mean that businesses may need to reassess which transactions are subject to mandatory split payment.

In practice, companies should review not only their internal procedures, but also the configuration of invoicing, accounting and payment systems.

4. Changes to import VAT settlements

The amendment also introduces changes relating to import VAT.

It provides certain facilitations for importers using customs simplifications and modifies the rules concerning interest.

Businesses engaged in regular import transactions may therefore need to reassess their customs procedures and the manner in which import VAT is accounted for.

5. Intra-Community acquisitions of means of transport

The amendment also changes the rules applicable to intra-Community acquisitions of means of transport.

Some payment obligations will be simplified, while the reporting rules will also change.

Businesses entering into such transactions should therefore review their settlement and reporting procedures.

6. Farmers operating a joint agricultural holding

The new rules also apply to farmers operating a joint agricultural holding.

They will be able to obtain separate VAT taxpayer status. At the same time, this will entail additional record-keeping and reporting obligations.

7. Abuse of law and VAT sanctions

Important changes also concern the rules relating to abuse of law and VAT sanctions.

The amendment covers, among other things:

• grounds for refusing the right to deduct input VAT,
• exclusions from the protection associated with the split payment mechanism,
• rules for imposing additional VAT liabilities.

In practice, these changes may directly affect the assessment of whether VAT settlement models and internal tax procedures remain sufficiently secure.

What do the changes mean for businesses?

From a practical perspective, three areas in particular deserve attention.

The first is contractor verification and the management of joint and several liability risks, especially in relation to the acquisition of services covered by the new provisions.

The second is the updating of procedures and accounting and payment systems in relation to mandatory split payment. Changes to the classification of goods may require companies to reassess the payment treatment of individual transactions.

The third area is a renewed review of VAT settlement security in light of the new provisions on abuse of law and tax sanctions.

The amendment introduces both new solutions and simplifications, but also additional risk areas that should be reflected in businesses’ tax compliance frameworks.

Companies should therefore assess which of the new rules will have a direct impact on their business model and internal processes.

For more information, please contact: grzegorz.arczewski@thedy.pl