When exporting from Poland to the UK you apply 0% VAT once the export is confirmed and lodge an export declaration, while the UK importer pays duty and UK VAT. Duty is 0% only for goods of EU preferential origin, shown by a statement on origin or the importer's knowledge.
Exporting to the United Kingdom after Brexit involves tax obligations on both sides of the Channel. On the Polish side: 0% VAT and an export declaration. On the UK side: the UK importer pays UK Customs Duty and UK VAT. Below we explain it step by step.
Questions and answers — PL→UK export: duties and taxes
What does 0% VAT on export mean?
0% VAT on export is not a VAT exemption, but a zero rate of tax. The difference matters: with an exemption you cannot deduct input VAT on purchases related to the export, whereas with the 0% rate you deduct it as normal. Export from Poland to the UK = 0% VAT rate, full right to deduct input VAT.
Key condition: You need a document confirming that the goods left the EU to apply the 0% rate; in practice this is the IE599 message from the AES system (the rules are set by Article 41 of the Polish VAT Act). Without such confirmation, the tax office may challenge the use of the 0% rate and require payment of tax at the domestic rate (23%).
What is IE599 and how do you obtain it?
IE599 is an electronic message from the AES (Automated Export System) confirming that goods have left EU territory. It is generated automatically once the goods have physically left the EU (confirmed by customs at the border exit point). The customs agency lodges the EX A declaration on your behalf and provides you with the IE599 — keep it as proof of export for your JPK (SAF-T) records.
How is the tax responsibility split on an export?
| Obligation | Polish side (exporter) | UK side (importer) |
|---|---|---|
| VAT | 0% + IE599 | UK import VAT at the rate for the goods, usually the 20% standard rate (Postponed VAT or payment at import) |
| Duty | None (export from the EU is duty-free) | UK Customs Duty under the UK Global Tariff (the rate depends on the commodity code; 0% for goods of EU preferential origin backed by a proof of origin) |
| Customs declaration | EX A in AES (export) | Import declaration in CDS HMRC (UK customs declaration) |
| Documents | Invoice (required fields), packing list, CMR, statement on origin (if the buyer is to claim TCA preference; see statement on origin and REX) | Import declaration in CDS; import VAT evidence: postponed import VAT statement (with PVA) or C79 certificate |
Do you need an EUR.1 certificate when exporting to the UK?
No. In EU–UK trade under the Trade and Cooperation Agreement (TCA), the EUR.1 certificate is not used. The proof of origin is a statement on origin made out by the exporter on the invoice or another commercial document, or the importer's knowledge (GOV.UK). An EU exporter sending consignments with a total value of more than EUR 6,000 must include their REX number in the statement. A statement can cover a single consignment or multiple shipments of identical products over a period of no more than 12 months.
Key condition: the 0% TCA rate applies only if the goods have EU preferential origin (they meet the TCA rules of origin) — shipping them from Poland does not settle this by itself. Without a valid proof of origin, your UK customer will pay duty under the UK Global Tariff.
What is Postponed VAT Accounting in the UK?
Postponed VAT Accounting (PVA) is a mechanism allowing a UK importer to account for import VAT on their VAT return instead of paying it in cash at the point of import. It works similarly to Article 33a of the Polish VAT Act (see Postponed VAT Accounting in the UK). Your UK customer, by using PVA, does not have to tie up cash in VAT on every delivery — this improves cash flow and makes purchasing from you more financially attractive.
How much does export handling by a customs agency cost?
The cost of handling by a customs agency is set individually — see how much customs clearance costs or ask for a quote.
Frequently asked questions
Is export to the UK exempt from VAT?
No, a 0% rate applies rather than an exemption, so you keep the right to deduct input VAT. It requires confirmation that the goods left the EU.
Who pays duty and VAT in the UK on exports from Poland?
In principle the UK importer: UK duty under the UK Global Tariff and UK import VAT, which can be accounted for on the VAT return through Postponed VAT Accounting.
Is an EUR.1 certificate needed when exporting to the UK?
No. In EU–UK trade the proof of preferential origin is the exporter's statement or the importer's knowledge. Above EUR 6,000 the statement must include the REX number.
Do goods from Poland always get 0% duty in the UK?
No. 0% applies only to goods of EU preferential origin backed by proof of origin. Without it, the importer pays duty under the UK Global Tariff.
What is Postponed VAT Accounting?
It is a mechanism that lets a UK importer account for import VAT on the VAT return instead of paying it at import.
Related guides
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