[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"advice-en-refaktura-reinvoicing":3},{"slug":4,"title":5,"excerpt":6,"body":7,"datePublished":8,"dateModified":8},"refaktura-reinvoicing","Reinvoicing in 2026: when to issue one and when a note is enough","Reinvoice vs expense refund: a four-question test, VAT rate on resold services, mark-up, moment of tax liability, KSeF and an accommodation example.","\u003Cp>A reinvoice is an ordinary invoice issued by an entrepreneur when they resell to a client a service bought in their own name but in fact for that client. The VAT Act does not use the word \"reinvoice\" (refaktura), but applies a legal fiction: a person who, acting in their own name, takes part in providing a service to a third party is treated as if they had themselves received and supplied the service. The most important thing in practice is distinguishing a reinvoice from an ordinary refund of outlays incurred in the client's name — because then no invoice is issued at all.\u003C\u002Fp>\n\n\u003Ch2>Reinvoice or refund — a simple test\u003C\u002Fh2>\n\u003Ctable>\n\u003Cthead>\u003Ctr>\u003Cth>Question\u003C\u002Fth>\u003Cth>Reinvoice\u003C\u002Fth>\u003Cth>Refund of outlays\u003C\u002Fth>\u003C\u002Ftr>\u003C\u002Fthead>\n\u003Ctbody>\n\u003Ctr>\u003Ctd>To whom was the purchase invoice issued?\u003C\u002Ftd>\u003Ctd>to your firm\u003C\u002Ftd>\u003Ctd>to the client (the firm only intermediates the payment)\u003C\u002Ftd>\u003C\u002Ftr>\n\u003Ctr>\u003Ctd>In whose name was the contract with the supplier concluded?\u003C\u002Ftd>\u003Ctd>in your own\u003C\u002Ftd>\u003Ctd>in the client's name, e.g. on the basis of a power of attorney\u003C\u002Ftd>\u003C\u002Ftr>\n\u003Ctr>\u003Ctd>Does the amount enter the VAT tax base?\u003C\u002Ftd>\u003Ctd>yes\u003C\u002Ftd>\u003Ctd>no, if the outlay is documented and recognised on a pass-through basis in the records\u003C\u002Ftd>\u003C\u002Ftr>\n\u003Ctr>\u003Ctd>Document for the client\u003C\u002Ftd>\u003Ctd>invoice (in KSeF)\u003C\u002Ftd>\u003Ctd>usually a debit note with a copy of the purchase document\u003C\u002Ftd>\u003C\u002Ftr>\n\u003C\u002Ftbody>\n\u003C\u002Ftable>\n\u003Cp>The Act expressly excludes from the tax base amounts received from the client as a refund of documented outlays incurred in the client's name and for their benefit. If, however, the firm itself ordered the service and received the invoice to its own name, we are dealing with a resale — and an invoice with VAT must be issued.\u003C\u002Fp>\n\n\u003Ch2>When the rules on reselling services apply\u003C\u002Fh2>\n\u003Cp>The reinvoice construct concerns services only. The resale of goods is simply their supply and is settled on general rules. Typical examples:\u003C\u002Fp>\n\u003Cul>\n\u003Cli>a construction firm orders transport and a crane and then charges the investor for them,\u003C\u002Fli>\n\u003Cli>a conference organiser buys accommodation and meals for participants registered by the client,\u003C\u002Fli>\n\u003Cli>a landlord resells to the tenant the security or common-area cleaning service,\u003C\u002Fli>\n\u003Cli>a group company buys licences or training for several related companies and splits the cost.\u003C\u002Fli>\n\u003C\u002Ful>\n\u003Cp>A separate issue is the settlement of utilities (electricity, water, heating) in a lease. Whether they are a separate supply or part of the rent depends on the contract and the tenant's ability to influence consumption — in such contracts the matter is worth resolving case by case.\u003C\u002Fp>\n\n\u003Ch2>VAT on the reinvoice: rate, moment and mark-up\u003C\u002Fh2>\n\u003Ch3>Rate and exemptions\u003C\u002Fh3>\n\u003Cp>Because the firm steps into the shoes of the service provider, it is accepted in practice that the resold service keeps its character. A reinvoiced hotel night is taxed as accommodation, and a VAT-exempt service (e.g. insurance) remains exempt. On a reinvoice the standard 23% rate should therefore not be applied automatically.\u003C\u002Fp>\n\u003Ch3>Tax obligation\u003C\u002Fh3>\n\u003Cp>The general rule applies: output VAT arises when the service is performed. For services settled in periods, e.g. monthly facility security, the service is deemed performed at the end of each settlement period. The date of purchase from the original supplier does not determine the date of the reinvoice — what counts is the performance of the service resold to the client.\u003C\u002Fp>\n\u003Ch3>Mark-up\u003C\u002Fh3>\n\u003Cp>The regulations do not prohibit adding a mark-up. The tax base is everything the firm receives from the client, so with a mark-up VAT is charged on the full amount. The lack of a mark-up is also admissible and does not mean the transaction loses its resale character.\u003C\u002Fp>\n\u003Ch3>Deduction\u003C\u002Fh3>\n\u003Cp>An active VAT payer deducts the tax on the purchase invoice on general rules, because the purchase serves a taxable activity. A firm exempt from VAT issues a reinvoice without tax and does not deduct VAT on the purchase.\u003C\u002Fp>\n\n\u003Ch2>Reinvoice in KSeF and in income tax\u003C\u002Fh2>\n\u003Cp>A reinvoice is an ordinary invoice, so from 2026 it is subject to the same rules as other invoices in the National e-Invoicing System: from 1 February 2026 for the largest firms, from 1 April 2026 for the rest, and the smallest entrepreneurs (sales up to PLN 10,000 per month) have time until 1 January 2027. The word \"refaktura\" is not a required element of the invoice; it can be placed in the description, but this does not change the settlement.\u003C\u002Fp>\n\u003Cp>In income tax, the amount from the reinvoice is revenue, and the purchase invoice is a tax-deductible cost. With a reinvoice without mark-up the result nets off, but both items must enter the records. This matters for limits that depend on the amount of revenue, e.g. the turnover-based VAT exemption limit or the small-taxpayer status.\u003C\u002Fp>\n\n\u003Ch2>Step-by-step example\u003C\u002Fh2>\n\u003Cp>An event agency (active VAT payer) organises a training trip for a client. In its own name it books 20 hotel nights at a hotel for PLN 8,000 net and receives the invoice to itself. The agreed mark-up with the client is 10%.\u003C\u002Fp>\n\u003Col>\n\u003Cli>The agency deducts VAT from the hotel invoice in its own settlement.\u003C\u002Fli>\n\u003Cli>After the stay it issues the client an invoice for PLN 8,800 net, applying the rate proper for accommodation services, not 23%.\u003C\u002Fli>\n\u003Cli>The invoice goes into KSeF; the description may include a note that it concerns the resale of hotel services.\u003C\u002Fli>\n\u003Cli>In PIT or CIT the agency reports PLN 8,800 of revenue and PLN 8,000 of cost.\u003C\u002Fli>\n\u003C\u002Fol>\n\u003Cp>If the hotel had issued the invoice directly to the client and the agency had only forwarded the payment, a debit note would be enough, with no VAT and no revenue at the agency.\u003C\u002Fp>\n\n\u003Ch2>Most common mistakes\u003C\u002Fh2>\n\u003Cul>\n\u003Cli>Applying the 23% rate to every reinvoice, regardless of the type of service.\u003C\u002Fli>\n\u003Cli>Issuing a debit note where the purchase invoice is made out to the reinvoicing firm.\u003C\u002Fli>\n\u003Cli>Setting the reinvoice date by the date of receipt of the supplier's invoice.\u003C\u002Fli>\n\u003Cli>Omitting reinvoices when calculating revenue limits.\u003C\u002Fli>\n\u003C\u002Ful>\n\u003Cp>The general VAT rules, rates and limits are described in the article \u003Ca href=\"\u002Fen\u002Fadvice\u002Fwhat-is-vat-in-poland\">VAT in Poland\u003C\u002Fa>.\u003C\u002Fp>\n\n\u003Ch2>How Good Balance can help\u003C\u002Fh2>\n\u003Cp>We help determine whether in a given situation a reinvoice or a note is needed, and prepare correct \u003Ca href=\"\u002Fen\u002Fservices\u002Finvoices\u002Ffaktura-vat\">VAT invoices, also in KSeF\u003C\u002Fa>. For clients keeping books of account we provide, as part of \u003Ca href=\"\u002Fen\u002Fservices\u002Faccounting\u002Ffull-accounting\">full accounting\u003C\u002Fa>, a coherent recognition of reinvoices in VAT, revenue and costs.\u003C\u002Fp>","2026-10-09"]