App Store and taxes: invoice to Apple, VAT-UE and PIT

A developer who publishes an app in the App Store does not formally sell it to users. Apple acts in its own name: it takes payment from the client, charges local VAT and pays the author after deducting commission. For a Polish entrepreneur this means one transaction a month — a service to the Apple company, documented by an invoice marked "reverse charge" and reported as revenue in the amount received.

Who is a party to the transaction

The Apple Developer Program licence agreement makes Apple an intermediary acting in its own name but for the benefit of the author. The VAT Act has a separate provision for such an arrangement: if a taxable person, acting in their own name, takes part in supplying a service to a third party, they are deemed to have themselves received and supplied the service (Article 8(2a)). The chain thus looks as follows:

• the end user buys the app or subscription from Apple, and Apple settles VAT in the client's country;
• the developer supplies a service (makes the app available for distribution) to the Apple company, which is a VAT taxpayer in another state.

Which company is the buyer is shown in the payment report in App Store Connect. For most European markets it is a company based in Ireland, but payments for part of the territories may come from another group entity. The invoice data is always worth comparing with the report and the buyer's VAT number checked in the EU VIES database.

An exception may be the alternative business terms Apple offers in the European Union. If the developer takes payments from users themselves, outside the Apple purchase system, in that part they become the seller to the consumer and, for clients from other EU states, the OSS procedure comes into play. Such a model must be analysed separately. A comparison of the app store with direct sales, advertising and sale of the entire app is given in the article on earning from a mobile app.

Apple's commission and the developer's revenue

The commission does not appear in the books as a cost. Since the developer supplies a service to Apple, their remuneration is the amount Apple owes them for the given period (in reports: "proceeds"). It is the amount that goes on the invoice and into the revenue register. The gross prices paid by clients and the VAT withheld are not the developer's revenue.

The amount of the commission therefore only affects the net amount from the report. In the Small Business Program the rate is 15% on paid apps and in-app purchases. New developers and those whose income from all apps in the previous calendar year did not exceed USD 1 million may join it. Linked accounts are counted towards the limit. After exceeding the threshold during the year, further sales are settled at the standard rate.

VAT: reverse charge and VAT-UE registration

A service to a taxable person from another EU state is taxed at their seat (Article 28b of the VAT Act). The Polish developer therefore does not charge VAT, and the tax is settled by the buyer. In practice:

• the invoice does not contain a VAT amount and contains the words "reverse charge" (Article 106e(1)(18));
• JPK_V7 — the transaction is reported as a supply of services outside the country's territory, in the part concerning services under Article 100(1)(4);
• VAT-UE recapitulative statement — the service is reported for the month in which the tax obligation arose;
• VAT-UE registration — is mandatory also for a VAT-exempt entrepreneur, if they supply such services to EU taxable persons (Article 97(3)(2)). The notification must be filed before the first transaction. Details are described in the article on VAT-UE registration.

Services supplied outside Poland do not fall within the statutory definition of sales (Article 2(22)), so they are not counted towards the turnover-based exemption limit, which in 2026 is PLN 240,000. A developer who earns only in the App Store may therefore stay VAT-exempt. VAT-UE registration is not, however, waived.

Invoice to Apple — what and when to issue

The simplest approach is to issue one aggregated invoice for each Apple payment period, for the amount from the report. The document should contain:

1. the full data of the Apple company from the report and its VAT-UE number;
2. your own VAT-UE number with the PL prefix;
3. a description, for example "Making the app available for distribution in the App Store — September 2026 settlement period";
4. the amount in the report's currency (most often euro or dollar), without a VAT rate;
5. the note "reverse charge".

A service settled in successive periods is deemed performed at the end of each period (Article 19a(3) of the VAT Act). The invoice is issued no later than on the 15th day of the month following that month (Article 106i(1)). Once the KSeF obligation applies, the invoice is issued in that system, and handed to the foreign buyer in an agreed way, for example as a PDF file. The smallest firms (sales up to PLN 10,000 per month) have this obligation from 1 January 2027.

PIT: revenue date, rate and form of taxation

Where the parties settle the service in settlement periods, revenue arises on the last day of the period set in the contract or on the invoice (Article 14(1e) of the PIT Act). The amount in foreign currency is converted at the average NBP rate announced on the last working day before the day on which the revenue was obtained (Article 11a(1)). The payment comes several weeks later and at a different rate. The difference is settled as a positive or negative exchange difference; the mechanism is described in the article on exchange differences.

App Store revenue is taxed under the form chosen for the business:

• tax scale or flat tax (podatek liniowy) — on income, i.e. after deducting costs (equipment, software, the annual developer account fee, advertising);
• ryczałt — on revenue, and the rate depends on how the service is classified. For sales through an app store the classification is sometimes disputed, so it is worth confirming before choosing the form of taxation;
• IP Box — if you created the app yourself and keep a record of work costs, income from a qualified right may be subject to the 5% rate. The conditions are described in the article on the IP Box relief.

Example of settling one month

The report for September 2026 shows EUR 2,400 of income due to the developer, who is registered as a VAT-UE taxpayer and exempt from VAT. The settlement period ends on 30 September.

1. An invoice to the Apple company for EUR 2,400, with the "reverse charge" note — issued by 15 October.
2. Revenue dated 30 September, converted at the NBP rate from 29 September (assume PLN 4.25), i.e. PLN 10,200.
3. A line in the September VAT-UE statement. A developer who is an active VAT payer also reports the transaction in JPK_V7.
4. Payment into the account in November at a rate of PLN 4.28, i.e. PLN 10,272. The surplus of PLN 72 is a positive exchange difference.

Most common mistakes

• Reporting revenue in the transfer amount instead of the amount from the report, even though the dates and rates differ.
• Booking Apple's commission as a cost, even though there is no invoice for it and the revenue is already the net amount.
• No VAT-UE registration by a VAT-exempt entrepreneur.
• An invoice issued to the wrong Apple company, without comparing it with the payment report.
• Skipping the VAT-UE statement, which is mandatory even with zero VAT.

How Good Balance can help

We help developers choose the form of taxation and arrange the monthly flow: from the App Store Connect report, through the invoice and KSeF, to JPK_V7 and VAT-UE. If the classification of revenue or eligibility for IP Box is doubtful, we prepare an application for an individual tax interpretation, and we handle current sales documents as part of the VAT invoicing service.