2025-04-02
Using ZAW-NR as „Last-Resort Lifeline” for Entrepreneurs
If you run business in Poland and make higher wire-payments exceeding PLN 15,000 to contractors (B2B), ensure the recipient’s bank account is listed in the official VAT taxpayer registry ( “white list”). Failure to verify this can jeopardise your CIT and/or VAT position. The "white list" was introduced to combat tax fraud in the so-called grey-zone, encouraging businesses to verify their contractor’s bank accounts. If the beneficiary’s account is on the “white list”, this means that he has notified it to the fiscal authorities.
If you run business in Poland and make higher wire-payments exceeding PLN 15,000 to contractors (B2B), ensure the recipient’s bank account is listed in the official VAT taxpayer registry ( “white list”). Failure to verify this can jeopardise your CIT and/or VAT position. The „white list” was introduced to combat tax fraud in the so-called grey-zone, encouraging businesses to verify their contractor’s bank accounts. If the beneficiary’s account is on the “white list”, this means that he has notified it to the fiscal authorities.
Otherwise, there is a risk that the authorities might not be aware of the need to monitor such account, thus making you an involuntary accomplice in potential tax fraud.
How to avoid the risk if such payment has already been made? Submit the ZAW-NR form!
Filing form ZAW-NR allows you to avoid negative CIT consequences, such as treating the expenses as non-deductible cost. Additionally, it protects you from joint liability for the contractor’s arrears on VAT related to your purchase .
What is ZAW-NR?
ZAW-NR is a notification to the tax office about a payment made to a non-listed account. It takes effect only when filed within 7 days from the first transfer to a given account.
When was ZAW-NR first introduced?
ZAW-NR form was introduced on January 1, 2020, as part of changes to income taxes (PIT and CIT) and VAT. Its primary purpose is to grant entrepreneurs a “last-resort lifeline” from the said negative consequences.
Who is it for?
Mostly Polish companies who want to keep their expenses tax-deductible and to avoid joint liability with the seller. However, also foreign companies might be interested in minimising the latter risk.
Restoring the deadline for filing ZAW-NR – is it possible?
Taxpayers only have 7 days to file ZAW-NR, starting from the date of their first payment to a non-listed account.
Unfortunately, this deadline cannot be extended, thus missing it may lead to serious tax consequences. On the bright side, once submitted, ZAW-NR provides protection for all future payments to the same account (even it is remains non-listed).
What if you miss the 7-days deadline?
There is no perfect solution, but here are two possible options that may help:
• Refund & Repayment – If the contractor is likely to have his account listed, ask him to return the original payment and then reprocess the payment once the account is “safe”.
• Refund & Payment to Another Account – If the contractor is unlikely to have any listed account, you might still ask him to return the payment, yet make the new payment to a different bank account (and file ZAW-NR withing 7 days from the second payment).
In option no. 2, avoid repaying to the same account as the original one, since this could be deemed an obvious circumvention of the rules.
See other articles
Poland’s draft bill UD116 could significantly change the tax treatment of certain entrepreneurs operating under B2B arrangements. The proposed rules would not abolish self-employment or Poland’s lump-sum tax regime on recorded revenue. However, they are intended to reduce the tax attractiveness of certain structures, particularly transactions with related parties, service businesses operating without employees, and the use of the Polish IP Box regime.
The Act of 29 May 2026 amending the Polish Tax Ordinance and certain other acts, signed by the President of Poland, introduces significant changes to the Polish rules on reporting tax schemes, commonly referred to as MDR, or Mandatory Disclosure Rules. The new MDR provisions are expected to enter into force on 1 October 2026 and will substantially narrow the scope of obligations which, since 2019, have been one of the more demanding elements of tax compliance in Poland.
Tax proceedings in Poland should not be a process in which only the tax authority decides which facts will be examined and which evidence will be taken into account. Under the Polish Tax Ordinance Act, taxpayers have the right to actively participate in proceedings, including the right to submit their own requests for evidence. In practice, however, not every piece of evidence proposed by a taxpayer will be admitted. When can the tax authority refuse an evidentiary request, and what options are available to taxpayers in such situations?
Determining when a VAT liability arises in relation to services remains one of the more challenging issues in practice under Polish VAT law. Although Article 19a(1) of the Polish VAT Act clearly states that VAT becomes due when a service is performed, establishing when a service is actually “performed” sometimes requires a case-by-case assessment of the contractual model and the underlying commercial reality. Recent Polish judgment by the Supreme Administrative Court of 31 March 2026 (I FSK 1353/23) provides important clarification in the context of IT services.
As the Polish National e-Invoicing System (KSeF) becomes more widely used, businesses are increasingly encountering a practical issue known as the “double document circulation.” This occurs when the structured invoice stored in KSeF (XML) differs from the PDF visualization sent to the customer, for example by email or through a customer portal.
On 11 February, the EU General Court (Case T-689/24) delivered an important judgment in a “Polish case” on the moment of input VAT deduction. The ruling may have far-reaching consequences for Polish businesses and the way VAT is settled in Poland.
Invoice Issued Outside KSeF and Tax-Deductible Costs. Key Position of the Polish tax administration.
Individual tax ruling of 9 January 2026, ref. 0111-KDIB1-3.4010.714.2025.2.JG In an individual tax ruling dated 9 January 2026, the Director of the Polish National Revenue Information (KIS) addressed an issue that has raised significant practical concerns in the context of the implementation of the National e-Invoicing System (KSeF). The key question was whether an expense documented by an invoice issued outside the KSeF-system may be treated as a tax-deductible cost for the purposes of Polish corporate income tax (CIT).
The introduction of the mandatory Polish e-invoicing system (Krajowy System e-Faktur – KSeF) as of 1 February 2026 will significantly change VAT invoicing rules, i.a. transactions involving foreign entities. One of the key factors determining whether mandatory KSeF applies is whether a foreign counterparty has a fixed establishment (FE) in Poland. If it is lacking on the seller’s side, then he may issue and send invoices outside KSeF (e.g. via e-mail, PDF). If the seller is subject to KSeF yet his buyer is not (lacking seat/FE in Poland), then the seller must issue the invoice via KSeF, yet simultaneously send it to his buyer in the old-fashioned way.
The general tax ruling issued by the Polish Minister of Finance and Economy on 27th of November 2025 addresses the issue of land, buildings and structures being deemed as “related to business activity”. It is one of the most significant documents in recent years in the area of property taxation. Its importance goes well beyond a purely technical explanation of statutory provisions. At its core, it touches on a fundamental and long-running dispute between taxpayers and tax authorities: where the line should be drawn between mere ownership of real estate and its use for business purposes.
Even though penalties for issuing invoices outside Poland’s National e-Invoicing System (KSeF) have been deferred until 1 January 2027, the real headache may come sooner.