Reverse charge (VAT) on UK–PL services — import of services, JPK and common mistakes

What the reverse charge is and when it arises on the UK–PL route

The reverse charge is a mechanism that shifts the obligation to account for VAT from the seller to the customer. Instead of adding the tax to the invoice and paying it over to the tax office, the seller issues an invoice without VAT, and the customer charges the output tax itself in its own country — and in the same return usually deducts it as input tax. In cross-border B2B services this is the standard way of accounting, and on the Polish side it operates under the name import of services.

On the UK–PL route the reverse charge arises in two directions. When a Polish company buys a service from a UK supplier (e.g. a software subscription, a marketing, consultancy, legal or intermediary service), the Polish customer accounts for the VAT. When a Polish company supplies a service to a company in the UK, the UK recipient accounts for the tax. In both cases the seller's invoice carries no VAT — instead it bears a note indicating that the customer accounts for the tax. This article reflects the legal position as at 2026-06-13. Speak to a customs agent or a tax adviser before taking any action.

This concerns services, not goods

The most important distinction up front: the reverse charge discussed in this article concerns services. If goods move across the border, VAT is accounted for under the import regime (and not as a reverse charge on services) — we return to this below, because it is precisely the confusion between these two regimes that is the most common mistake.

The Polish side: import of services (Article 28b and Article 17 of the Polish VAT Act)

Where a service bought by a business is taxed is determined by the place of supply. Under Article 28b(1) of the Polish VAT Act, the place of supply of services to a taxable person is, as a rule, the place where the customer has established its business. For a Polish company buying a service from a UK counterparty, this means the place of taxation is Poland.

So who pays the tax? This is answered by Article 17(1)(4) of the Polish VAT Act: the person liable for the tax on the import of services is the customer, provided the supplier has neither its registered office nor a fixed establishment in Poland and is not VAT-registered there, and the customer is a taxable person (an active VAT payer or a legal person required to register). For a typical Polish company buying a service from the UK, these conditions are met — it is the company that accounts for the VAT.

The mechanism is as follows:

1. Output VAT — the Polish company charges tax on the net value of the service at the applicable Polish rate (usually 23%).
2. Input VAT — at the same time it deducts that same tax if the purchase serves taxable activity. The transaction is then cash-neutral (no tax is paid out of pocket).
3. No right to deduct — if the purchase serves exempt activity, the output VAT remains a real cost.

After Brexit the mechanism is the same, but the UK is a third country

Since 1 January 2021 the United Kingdom (England, Wales, Scotland) has, for VAT purposes, been a third country. The way the import of services is accounted for has not changed — the Polish VAT Act does not distinguish whether the supplier comes from the EU or from outside it. The UK is treated like any other supplier from outside the Union. One important thing has changed, however: the purchase of services from a UK entity is no longer an intra-Community transaction, so it is not reported in the VAT-UE recapitulative statement.

How to report the import of services from the UK in JPK_V7

In the JPK_V7 file the import of services is recorded on both sides — on the output side (because it is the customer who is the taxable person) and the input side (because the deduction is available). The key point is the correct output field, because the legislature separates services from outside the EU from services from the EU:

• K_27 / K_28 — taxable base and output VAT on the import of services excluding services from EU taxable persons (Article 28b). This is where services from a UK supplier go, as a third country.
• K_29 / K_30 — import of services acquired from taxable persons in EU states (Article 28b). These fields are not used for the UK.
• K_42 / K_43 — on the purchase side: net value and input VAT available for deduction (other acquisitions, including the import of services).

According to the Ministry of Finance information brochure for the JPK_V7 structure, the GTU markers do not apply to transactions that give rise to output tax on the customer's side (including the import of services). The numbering of fields K_27–K_30 applies in the current JPK structure; if you are accounting for periods before the current version, verify the numbering in the relevant Ministry of Finance brochure.

What if the company is VAT-exempt?

An entity benefiting from a VAT exemption (e.g. on account of the turnover threshold) that buys a service from a UK counterparty is also a taxable person in respect of the import of services. It then files a VAT-9M return and pays the VAT by the 25th day of the month following the month in which the tax point arose. In this case — with no right to deduct — the tax paid is a real cost.

The UK side: reverse charge under VAT Notice 741A

Mirror rules apply where it is a UK company buying a service from a Polish (or other foreign) supplier. HMRC describes the mechanism in VAT Notice 741A "Place of supply of services" (the section on the reverse charge). The UK customer charges the tax to itself and deducts it at the same time, making entries on the VAT Return:

• Box 1 — output tax on the value of the service;
• Box 4 — input tax available for deduction;
• Box 6 and Box 7 — the full value of the service on the sales and purchases sides respectively.

In most cases Box 1 and Box 4 cancel each other out, so the effect is neutral. HMRC notes, however, that applying the reverse charge is not optional: even if the supplier had wrongly added VAT, the UK customer must still account for the tax under the reverse charge mechanism and should ask the supplier to correct the invoice.

For a Polish company selling services to the UK, the practical takeaway is this: you issue an invoice without Polish VAT, with a note indicating that the customer accounts for the tax, and the UK VAT accounting rests with the recipient. Where the transaction structure is more complex (e.g. services connected with property in the UK), it is worth checking whether an obligation to register for VAT in the UK or a need for a fiscal representative arises.

The most common mistake: confusing services (reverse charge) with the import of goods (PVA)

This distinction deserves its own paragraph, because it causes the most stress and corrections. The reverse charge discussed above concerns services. When, by contrast, a company brings goods into the UK, VAT is due as import VAT — and it is accounted for under a different regime. VAT-registered UK businesses usually use Postponed VAT Accounting (PVA), declaring import VAT on the return rather than paying it in cash at the border.

Interestingly, PVA also technically results in an entry on the output side (Box 1) and the input side (Box 4) — and it is precisely this surface similarity that leads to mistakes. Even so, these are two separate mechanisms: the reverse charge on services is governed by VAT Notice 741A, while the import of goods is governed by the rules on import and PVA. Duty and VAT, in turn, are two different charges, which we explain in the article on the difference between duty and VAT. So if physical goods move on the UK–PL route, do not look for the answer in the rules on services.

The UK domestic reverse charge is yet another thing

To round off the topic: the United Kingdom also has a domestic reverse charge, described in VAT Notice 735. It applies to transactions between UK VAT-registered taxable persons in selected sectors — including construction services covered by the CIS (from 1 March 2021), mobile phones and integrated circuits, and wholesale energy trading. This is a third, entirely separate mechanism — it should not be confused with the cross-border reverse charge on UK–PL services.

In practice: invoice, documentation, records

A few practical rules that reduce the risk of a dispute with the tax office:

• Invoice for a service supplied to the UK — without Polish VAT, with a clear note such as "odwrotne obciążenie" / "reverse charge", indicating that the customer accounts for the tax.
• Invoice for a service bought from the UK — usually without VAT; the Polish company accounts for the import of services itself, recording the invoice in its books as the basis for charging the tax.
• Consistency with JPK — the amounts in the records must match the JPK_V7 fields (K_27/K_28 on the output side for services from outside the EU, K_42/K_43 on the input side).
• EORI — not needed to buy services; it relates solely to the movement of goods. If you are just starting to import goods, check what an EORI number is.

The role of the customs agent and the adviser

Although accounting for the import of services itself sits on the accounting side, in practice the line between "a service accounted for under the reverse charge" and "a goods transaction requiring clearance and import VAT" can be thin — especially with services tied to the supply of goods, assembly or logistics. This is where a customs perspective helps: correctly classifying the transaction, establishing whether an obligation to register for VAT in the UK arises, and putting the documentation in order. Easy Clearance supports Polish companies trading with the UK on the customs and border side — get in touch if you are not sure whether your transaction is a service or an import of goods.

What follows from the current rules

For B2B services on the UK–PL route, VAT is accounted for by the customer in its own country under the reverse charge mechanism. On the Polish side this is the import of services: the place of supply is set by Article 28b of the Polish VAT Act (the customer's place of establishment), and Article 17(1)(4) makes the customer the taxable person — the company charges output VAT and usually deducts it as input VAT. After Brexit the mechanism remained the same, but the UK is a third country, so the transaction is not reported in VAT-UE, and in JPK_V7 it goes into the fields for services from outside the EU (K_27/K_28). On the UK side the reverse charge is governed by VAT Notice 741A (Box 1 and Box 4). It is essential not to confuse the reverse charge on services with the accounting for the import of goods (PVA), nor with the UK domestic reverse charge (Notice 735). This article reflects the legal position as at 2026-06-13. Speak to a customs agent or a tax adviser before taking any action.

FAQ — frequently asked questions

Who accounts for VAT when a Polish company buys a service from a UK company?

The Polish customer. For B2B services the place of taxation is the customer's place of establishment (Article 28b of the Polish VAT Act), and the person liable for the tax on the import of services is the customer (Article 17(1)(4)). The Polish company charges output VAT at the Polish rate and at the same time deducts the input VAT if the purchase serves taxable activity — the transaction is then neutral.

Is the import of services from the UK accounted for differently after Brexit?

The mechanism itself has not changed — the customer still accounts for it. What has changed is the classification: since 1 January 2021 the UK is a third country, so the purchase of services from the UK is not reported in the VAT-UE recapitulative statement, and in JPK_V7 it goes into the fields for the import of services from outside the EU (K_27/K_28), not the fields for services from EU taxable persons (K_29/K_30).

How does the reverse charge on services differ from the import of goods (PVA)?

They are two different mechanisms. The reverse charge applies to services. The import of goods into the UK is accounted for as import VAT — UK businesses usually use Postponed VAT Accounting (PVA), declaring import VAT on the return rather than paying it at the border. Both produce an entry on the output and input side, but they are governed by different rules.

How is a service bought from a Polish company accounted for on the UK side?

The UK customer applies the reverse charge in line with VAT Notice 741A. It accounts for output tax in Box 1 and input tax in Box 4, and the value of the service in Box 6 and Box 7. HMRC stresses that this is not optional — the reverse charge applies mandatorily, even if the supplier had wrongly added VAT.

Do I need an EORI number to buy a service from the UK?

No. The EORI relates to the movement of goods across the customs border, not the purchase of services. The import of services is settled purely under VAT rules. You will only need an EORI once you start importing or exporting goods.

Official sources

• Place of supply of services (VAT Notice 741A) — gov.uk HMRC — GOV.UK
• Domestic reverse charge procedure (VAT Notice 735) — gov.uk HMRC — GOV.UK
• Complete your VAT Return to account for import VAT (Postponed VAT Accounting) — gov.uk — GOV.UK
• Ustawa z 11 marca 2004 r. o podatku od towarów i usług (art. 17, art. 28b) — ISAP — ISAP / Sejm RP
• JPK_VAT z deklaracją — broszura i struktura (pola K_27–K_30, K_42–K_43) — podatki.gov.pl — Ministry of Finance