Ruling – How to tax VAT on chain deliveries from Poland to Asia?

Source TA&TPT

Unoficial translation

Individual Ruling No. 0113-KDIPT1-2.4012.341.2020.3.IR of 20.08.2020 applies to a Polish company dealing with the purchase and sale of scrap metal. Due to the lack of its own warehouses, the company has arranged its supply chain in such a way that it purchases scrap directly from a supplier from Poland using incoterms 2010 EXW, then resells it using incoterms 2010 from group C to entities from Asia, while exporting scrap to Asia.

When applying for an individual interpretation, the company wanted to confirm the correctness of the adopted method of accounting for supplies made by a supplier from Poland to the company as an export of goods, to which the 0% VAT rate applies, and supplies of the company to entities from Asia as non-taxable transactions in Poland.

In response to the request, the Director of the National Tax Information Office stated that the Polish supplier makes domestic supplies subject to taxation in Poland, and the company’s supplies to Asian entities constitute exports of goods. The deliveries made by the company are mobile (international) deliveries and it is these deliveries that benefit from the 0% rate preference.

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