A seller who starts selling to consumers in the EU usually asks the same first tax question: "Do I need a separate VAT registration in every country?" Most of the answer lies in three abbreviations: OSS, non-Union OSS and IOSS. This article explains what these schemes are, which one fits whom, and how they are used in Poland. Marketplace details are in separate articles: Allegro and Amazon (.pl/.de).
Short answer: OSS (One Stop Shop) is an optional scheme that lets you pay the VAT on sales to consumers in other EU countries in a single country, with a single return. Since 1 July 2021 it has three forms: the Union OSS for sellers established in the EU, the non-Union OSS for services supplied to consumers by businesses outside the EU, and IOSS for imported consignments worth no more than EUR 150. OSS covers only sales to consumers (B2C); it does not cover sales of goods stored in another country within that country.
What the 2021 EU e-commerce VAT package changed
According to the European Commission's explanatory notes, the package that took effect on 1 July 2021 changed the EU VAT Directive (2006/112/EC, as amended by Directives 2017/2455 and 2019/1995) on four points:
- The old distance-selling thresholds, which differed country by country, were abolished and replaced by a single EU-wide EUR 10,000 threshold.
- The former Mini One Stop Shop (MOSS) for services to consumers was extended and renamed OSS; intra-EU distance sales of goods came into its scope.
- The VAT exemption on imported consignments up to EUR 22 was removed; IOSS (Import One Stop Shop) was created for imported consignments up to EUR 150.
- Marketplaces facilitating sales started, in certain cases, to be treated as the seller for VAT purposes (deemed supplier).
The EUR 10,000 threshold: what happens below and above it
The threshold looks at the total of your intra-EU distance sales of goods (goods sent from one EU country to a consumer in another EU country) and your telecommunications, broadcasting and electronic services to consumers. It is not counted per country: the total of these sales to all EU countries counts, and the amount excluding VAT must not exceed EUR 10,000 in either the current or the previous calendar year. biznes.gov.pl also gives the same threshold as PLN 42,000. Domestic sales in Poland and sales to businesses (B2B) are not part of this total.
- Below the threshold: the sale is treated like a domestic sale; if you ship from Poland, Polish VAT applies. If you wish, you can opt for the buyer's country VAT below the threshold as well; this choice binds you for two calendar years.
- Above the threshold: the VAT rate of the country the goods are sent to applies. You pay this VAT either through a separate VAT registration in each buyer country or in a single return through OSS.
The threshold applies only to a seller established in a single EU country who ships the goods from that country. There is no threshold for a seller established outside the EU; the buyer's country VAT arises from the first sale. We do not list country rates here; current rates are in the Commission's tax database (TEDB).
Three schemes: Union OSS, non-Union OSS, IOSS
According to the Commission's OSS guide, all three schemes are optional; but once you choose one, you must declare all your sales that fall under that scheme, for all countries, through it. The OSS return does not replace your domestic VAT return; it comes in addition to it.
- Union OSS (procedura unijna). For a seller established in the EU: intra-EU distance sales of goods and services to consumers in countries where you are not established. A seller established outside the EU can also use this scheme, but only for goods dispatched from within the EU; in that case the country of registration is the country where the goods start their journey. Returns are quarterly.
- Non-Union OSS (procedura nieunijna). For services supplied to consumers in the EU by a business not established in the EU; for example, an online service sold by a company in Turkey to consumers in the EU. Sales of goods do not fall under this scheme. Returns are quarterly.
- IOSS (procedura importu). For sales to consumers in consignments sent from outside the EU with an intrinsic value not exceeding EUR 150; excise goods excluded. Returns are monthly. A seller established outside the EU must, as a rule, appoint an intermediary (pośrednik) established in the EU; the exception given by the Commission is countries with which the EU has a mutual assistance agreement on VAT (for example, Norway). If the customs declaration carries a valid IOSS number, the import is exempt from VAT; the VAT is collected from the buyer at the time of sale and paid through the IOSS return.
Which scheme fits you: three typical cases
1. Small parcels from Turkey to consumers in the EU
If goods are shipped one by one from Turkey, this is an import; the relevant scheme is IOSS, not OSS. If the consignment value does not exceed EUR 150, you can register for IOSS through an EU intermediary, or sell through a marketplace that uses IOSS. The marketplace is the deemed supplier for such a sale and calculates and pays the VAT. IOSS cannot be used for consignments above EUR 150; import VAT and customs formalities follow the normal rules. For customs and A.TR, see the Expand to Europe page.
2. A Turkish-owned Polish company selling from a Polish warehouse to the EU
A limited company registered in Poland (Sp. z o.o.) is a seller established in the EU. A sale from a Polish warehouse to a consumer in Czechia or Germany is an intra-EU distance sale. Below the EUR 10,000 total, Polish VAT applies; above it, the buyer's country VAT arises and is paid in Poland in a single return under the Union OSS. No VAT registration is needed in the other countries, as long as the goods leave from Poland. Sales within Poland and sales to businesses (intra-Community supply, WDT) go into the normal Polish return, not into OSS.
3. Marketplace warehouses in other EU countries
If the goods sit in a marketplace warehouse in Germany and go from there to a consumer in Germany, the sale is a domestic sale in Germany. The Union OSS covers only sales where the goods move from one country to another; sales of goods stored in another country within that country do not fall under OSS and require VAT registration in that country. The VAT consequences of moving goods between warehouses need to be planned separately with the certified accountant partner. Details are in the Amazon (.pl/.de) article. There is one exception: if a seller established outside the EU sells goods located within the EU to a consumer through a marketplace, the marketplace becomes the deemed supplier under Article 14a(2) of the Directive.
OSS and IOSS registration and returns in Poland
According to the OSS and IOSS page on podatki.gov.pl and biznes.gov.pl, the process in Poland is as follows:
- Competent office: Drugi Urząd Skarbowy Warszawa-Śródmieście in Warsaw; all OSS and IOSS registrations and returns go there.
- Registration forms: VIU-R for the Union OSS, VIN-R for the non-Union OSS, VII-R for IOSS. According to biznes.gov.pl, VIU-R can also be filed through e-Urząd Skarbowy (the tax administration's online service portal) since 1 February 2025.
- Returns: VIU-DO for the Union OSS and VIN-DO for the non-Union OSS quarterly; VII-DO for IOSS monthly. They are filed through the e-Deklaracje system by the end of the month following the end of the return period. If there were no sales in the period, a nil return is filed.
- Payment: in euro, within the return deadline, to the office's account designated for OSS and IOSS; the transfer title carries the unique reference number (UNR) assigned to the return. A payment to the personal tax account (mikrorachunek) is not forwarded to the countries of consumption.
- Records: records of OSS and IOSS transactions are kept for 10 years from the end of the year in which the transaction took place.
The most common mistakes
- Counting the threshold per country. EUR 10,000 is the total of distance sales to all EU countries.
- Assuming OSS is enough for warehouses. A sale from a warehouse in another country to that country requires registration there.
- Putting B2B and domestic sales into the OSS return. OSS is only for cross-border consumer sales; input VAT is not deducted in the OSS return either.
- Using IOSS for consignments above EUR 150 or for goods already stored in the EU. Both are out of scope.
- Paying to the wrong account or omitting the UNR; the payment does not reach the country of consumption.
- Skipping the nil return. A return is filed even for a period with no sales.
Frequently asked
Is OSS registration mandatory?
No, it is optional. But once you exceed the EUR 10,000 threshold, the buyer's country VAT arises, and without OSS you need a separate VAT registration in each buyer country. For most sellers, OSS means less work.
Can I use OSS with my company in Turkey?
For services you can use the non-Union OSS. For sales of goods, the Union OSS is available only for goods dispatched from within the EU, with registration in the country the goods leave from; for small parcels sent from Turkey the relevant scheme is IOSS, and an EU intermediary is needed.
Do invoices for OSS sales go through KSeF?
Invoices issued to consumers are optional in KSeF; invoices issued to businesses go through KSeF. Details are in the KSeF article.
How we run it
We map out together your sales channels, where the goods are stored and whom you sell to, and set out in a written summary which scheme fits you. We keep the registration and filing calendar and explain Polish correspondence in Turkish. OSS and IOSS registration, the returns and the final tax assessment rest with our certified accountant partner; IOSS intermediary services and VAT registrations in other countries are handled with partners licensed in that field. We do not give tax advice; we make sure you reach the right specialist with the right question.
Sources
- VAT One Stop Shop (OSS) portal — European Commission
- Explanatory Notes on VAT e-Commerce — European Commission
- Guide to the VAT One Stop Shop — European Commission
- Punkt kompleksowej obsługi (OSS i IOSS) — Ministry of Finance, podatki.gov.pl
- How to account for VAT on sales to EU consumers — biznes.gov.pl
- Taxes in Europe Database (VAT rates) — European Commission
Last checked: 26 September 2026. This article is general information; your own case needs assessment by a licensed partner.
Tell us your situation or see the Expand to Europe page.
This article is for information only and is not legal or tax advice. Basis: the EU VAT Directive (2006/112/EC, as amended by Directives 2017/2455 and 2019/1995), the European Commission's explanatory notes on VAT e-commerce and its OSS guide, the Polish Ministry of Finance's OSS and IOSS page and biznes.gov.pl guidance; as of September 2026. For your own sales model the last word rests with our certified accountant partner.
Author
Savaş Dere · Founder, CEO
Close to twenty years in software and e-commerce: web and application development, automation, digital products. At Senavia he runs process design, the technology infrastructure and integrations; a founder who has been through company formation and settling in Poland himself.
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