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ARPI Accounting

VAT Guide, part 4: VAT Registration

VAT registration is one of the first and most important obligations faced by entrepreneurs starting a business or planning to conduct taxable activities. Although regulations in many cases require registration before the first sale subject to VAT, not every taxpayer is obliged to do so. Some entrepreneurs may benefit from VAT exemption, while others choose to register voluntarily.

Taxpayers who qualify as VAT-exempt taxpayers (due to the nature of the service) or VAT-exempt taxpayers (due to the PLN 240,000 limit) are not required to register as VAT-exempt taxpayers using the VAT-R form. They can do so voluntarily. On the other hand, some taxpayers must register for VAT upon starting their business, or those who will be required to do so due to transactions (e.g., exceeding the VAT limit, selling goods that are definitively subject to VAT).

Furthermore, the VAT registration requirement does not apply to taxpayers who have appointed a tax representative as defined in Article 18d, Section 1 of the VAT Act.

How VAT registration works

VAT registration is submitted on the VAT-R form (according to the specified template) to the appropriate head of the tax office. However, if VAT registration is being completed at the stage of establishing a business, this can be done together with an application to the Central Registration and Information on Business (CEiDG). Registration should be submitted before the first VAT-liable transaction is performed – i.e., no later than the day before the first taxable transaction is performed.

Furthermore, the registration form allows the taxpayer to specify whether, as a small taxpayer, VAT will be settled using the cash method, or whether they choose monthly or quarterly payment.

VAT registration can also be submitted through a proxy – however, one aspect should be particularly considered. Pursuant to Article 98, Section 4b, if the registration is submitted through a proxy, the proxy will be jointly and severally liable for any tax arrears incurred within six months of the registration date, up to PLN 500,000. Therefore, acting as a VAT registration representative may expose you to problems if the taxpayer fails to settle its VAT liabilities.

Verification of the Registration Application

After submitting the VAT-R registration application, the head of the relevant tax office verifies the data provided by the taxpayer. Primarily, this verification is intended to confirm that the taxpayer actually exists and intends to conduct business at the specified address. In practice, the tax office requests the taxpayer to provide legal title to the premises where they conduct/will conduct business (e.g., a lease agreement, loan agreement). Only after actual verification by the head of the tax office is the taxpayer registered for VAT purposes.

Furthermore, the tax office may refuse VAT registration if one of the following circumstances occurs:

  • the taxpayer’s data provided in the application is incorrect,
  • the entity does not exist,
  • the entity submitting the registration cannot be contacted,
  • the entity fails to respond to a summons to the tax authority,
  • the entity has been prohibited from conducting business activities by a court.

Currently, submitting the form is free of charge. However, if the application is submitted through a proxy, a power of attorney stamp duty of PLN 17 must be paid. You can also request confirmation of your VAT registration as an active or exempt taxpayer. In such a case, the stamp duty for issuing the confirmation will be PLN 170.