Unregistered business activity (działalność nierejestrowana) does not close the door to foreign clients — a translator, graphic designer or programmer can work for companies in Germany or the United States without registering in CEIDG. The most formalities appear with services for businesses from other European Union countries: before the first such service, you must register as a VAT-UE payer and file a monthly recapitulative statement each month, even though the VAT exemption itself is preserved. The general rules of this form, including the quarterly limit of PLN 10,813.50 in 2026, are described in the article Unregistered business activity 2026 — limits, rules and who it is for.
Why VAT matters here at all
Under the Entrepreneurs' Law such activity is not a business, but for the VAT Act a person who regularly sells services is a taxpayer. Usually they use the turnover-based VAT exemption up to PLN 240,000 of annual sales, so they do not charge VAT. With foreign clients, however, the key question is different: in which country is the service taxed at all. The answer determines whether additional obligations arise.
Where the service is taxed — four situations
| Client | Place of taxation (general rule) | What it means in practice |
|---|---|---|
| Business from another EU country | client's country (art. 28b) | VAT is settled by the client; the provider must have VAT-UE registration and file the recapitulative statement |
| Business from outside the EU | client's country (art. 28b) | service outside Polish VAT; no recapitulative statement |
| Private individual from the EU | Poland (art. 28c) | the turnover-based VAT exemption works as with a domestic client |
| Private individual from outside the EU | usually Poland; for some services the client's country (art. 28l) | e.g. consulting services, translations, data processing or advertising are taxed outside the EU |
There are exceptions to the general rule, including services related to real estate, transport or electronic services provided to EU consumers (for the latter an annual threshold of EUR 10,000, i.e. PLN 42,000 applies). For an unusual order, it is therefore worth checking the place of taxation before issuing a document.
Client from the European Union: registration as a VAT-UE payer
Article 97(3)(2) of the VAT Act requires exempt taxpayers who provide services taxed at an EU buyer to register in the register of VAT-UE payers. The notification must be submitted before the day the first such service is performed. VAT-UE registration does not turn a person conducting unregistered business activity into an active VAT payer — they still do not add tax to their invoices.
After registration there is an obligation to file the VAT-UE recapitulative statement. It is submitted electronically, for monthly periods, by the 25th day of the month following the month the service was performed. It shows clients' VAT numbers and the value of services. Practical issues, including the VAT-R form, are discussed in the guide VAT-UE registration.
Watch out for the reverse direction: when a person with unregistered business activity buys services from foreign companies (e.g. a software subscription), an obligation to settle import of services may arise. This is a separate topic that requires separate analysis.
Do foreign services eat into the PLN 240,000 limit
The turnover-based VAT exemption limit covers the value of "sales", which the VAT Act defines, among other things, as paid provision of services on the country's territory. Services whose place of taxation is the client's country, as a rule, do not fall within this definition. In unregistered business activity the quarterly revenue limit from the Entrepreneurs' Law is more important anyway — it covers all revenue, regardless of the client's country.
Currency, quarterly limit and PIT
For clients paying in euros or dollars, two different calculations should be kept in mind:
- The quarterly limit is calculated from revenue due, i.e. also from amounts invoiced but not yet paid. Their value should be converted cautiously, with a margin for exchange rate fluctuations.
- Income tax is calculated from amounts actually received. Revenue in foreign currency is converted into zlotys at the average NBP rate from the business day preceding the receipt of money (art. 11a of the PIT Act).
- Income is settled on the PIT-36 return by 30 April of the following year, with no advance payments during the year.
Some countries withhold tax at source on remuneration paid to foreign service providers. It can usually be reduced by giving the client a certificate of tax residence, and the tax paid abroad can be included in the Polish return under the rules of the double taxation treaty.
What document to issue to the client
In unregistered business activity there is no obligation to issue invoices, but the client may request an invoice within 3 months from the end of the month in which the service was performed or payment received. Foreign businesses almost always ask for one. On a document for an EU business it is worth providing their VAT number and the annotation "reverse charge", and for a non-EU client — a note that the service is not subject to taxation in Poland. The document can be prepared bilingually.
Example: a translator and an agency in Vienna
Ms Marta conducts unregistered business activity and performs translations for an Austrian agency. She is to deliver the first order, worth EUR 1,800, in February 2026. In January she files a VAT-R notification marking registration as a VAT-UE payer. After completing the service she issues an invoice without VAT with the annotation "reverse charge", and by 25 March she files the recapitulative statement for February. At an exchange rate of around PLN 4.25 the quarterly revenue is about PLN 7,650, so it fits within the PLN 10,813.50 limit. If a second order of this size came in March, the limit would be exceeded and within 7 days she would have to register a business.
The most common mistakes
- Performing a service for an EU business without prior VAT-UE registration.
- Forgetting about the monthly recapitulative statement in months when sales occurred.
- Converting revenue at the rate from the day it arrived in the account instead of the preceding business day.
- Assuming that every service for a private individual from outside the EU is taxed in Poland.
How Good Balance can help
We determine the place of taxation of services, carry out VAT-UE registration, file recapitulative statements and settle PIT-36 with foreign-currency revenue. When cooperation with foreign clients grows beyond the limit, we help set up a business as part of the sole proprietorship support service, and we prepare documents for clients as part of the invoice issuance service.