It is worth remembering commercial transactions in which more than two entities are involved, e.g. additionally an intermediary. It is about the so-called chain transactions. At the end of the transitional period, both Polish and British taxpayers will be required to carry out additional registration formalities or corresponding changes to the chain transactions used.


The German company sells goods to a company in the UK, which then resells them to a Polish entity, while the transport of the goods takes place directly from Germany to Poland. Such a transaction would generally require registration of a UK entity in Poland for VAT purposes. The transport ends in Poland, and that is where the transaction would be subject to VAT.

In such a situation, however, the regulations allow for simplification – the so-called triangulation. The condition that allows applying the simplification is the participation of three entities from the Member States. At the end of the transitional period, simplification will not apply as the condition of the involvement of three entities registered for VAT in three different Member States will not be met (if the UK company has no other VAT registration).


In the situation described in the earlier example, the simplification is that an entity from the United Kingdom would not have to be registered for VAT in Poland, and any VAT settlement in Poland would be made by the final purchaser – the Polish company. At the end of the transitional period, if the UK company will not have another VAT registration, it will be obliged to register in Poland for VAT purposes (and to appoint a tax representative) and settle the ICA transaction from Germany, and then domestic sales to the Polish taxable person.

Similarly, there may be consequences for Polish traders involved in chain transactions to the UK (i.e. the need to register for VAT in the UK for import and further sales purposes).

In conclusion, companies trading with the UNITED KINGDOM, in particular within the supply chain, will have to analyze their transactions and redefine its consequences in VAT. In some cases, VAT registration in another country may be required, and thus include additional administrative costs. Read more about our Fiscal representative service