Poland tax authority updates rules on premature invoicing

The National Revenue Administration has implemented a change in interpretation regarding prematurely issued invoices. Previously, issuing an advance or service invoice more than 30 days before payment could lead tax authorities to classify the document as a ‘empty invoice,’ resulting in severe penalties and mandatory immediate VAT payments.

A new individual interpretation issued in July 2025 aims to rationalize these rules. The change ensures that entrepreneurs who issue invoices ahead of schedule are not automatically treated as having issued fraudulent documents, providing greater legal certainty and reducing the need for constant corrections.