Proposal for a COUNCIL IMPLEMENTING DECISION amending Decision 2009/790/EC authorising the Republic of Poland to apply a measure derogating from Article 287 of Directive 2006/112/EC on the common system of value added tax
Date: 2021-08-09
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: Poland, VAT, derogation from EU law, small business, tax exemption

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   EUROPEAN COMMISSION  Brussels, 9.8.2021  COM(2021) 441 final 2021/0252 (NLE)  Proposal for a COUNCIL IMPLEMENTING DECISION amending Decision 2009/790/EC authorising the Republic of Poland to apply a measure derogating from Article 287 of Directive 2006/112/EC on the common system of value added tax  
 
EXPLANATORY MEMORANDUM 

Pursuant  to  Article  395(1)  of  Council  Directive  2006/112/EC  of  28  November  2006  on  the 
common system of valued added tax1 (‘the VAT Directive’), the Council, acting unanimously 
on  a  proposal  from  the  Commission,  may  authorise  any  Member  State  to  apply  special 
measures  for  derogation  from  the  provisions  of  that  Directive  in  order  to  simplify  the 
procedure for collecting VAT or to prevent certain forms of tax evasion or avoidance. 

By letter registered with the Commission on 1 March 2021, Poland requested authorisation to 
continue applying the derogating measure consisting in granting a VAT exemption to taxable 
persons whose annual turnover is no higher than the equivalent in national currency of EUR 
40 000 until 31 December 2024. 

In accordance with Article 395(2) of the VAT Directive, the Commission informed the other 
Member States by letter dated 25 March 2021, and Cyprus on 26 March 2021 of the request 
made by Poland. The Commission notified Poland by letter dated 29 March 2021 that it had 
all the information necessary to consider the request. 

1. 

• 

CONTEXT OF THE PROPOSAL 

Reasons for and objectives of the proposal 

Chapter 1 of Title XII of the VAT Directive allows for the possibility for Member States to 
apply  special  schemes  for  small  enterprises,  including  the  possibility  of  exempting  taxable 
persons below  a certain  annual  turnover. This  exemption  implies that a taxable person  does 
not have to charge VAT on his supplies and, consequently, he or she cannot deduct the VAT 
on his inputs. 

Under  Article  287  of  the  VAT  Directive,  particular  Member  States  which  acceded  after 
1 January 1978  may  exempt  taxable  persons  whose  annual  turnover  is  no  higher  than  the 
equivalent  in  national  currency  of  the  amounts  at  the  conversion  rate  on  the  day  of  their 
accession as specified in that provision. 

Under  point  14  of  Article  287  of  the  VAT  Directive,  Poland  may  exempt  taxable  persons 
whose annual turnover is no higher than the equivalent in national currency of EUR 10 000. 

By  Council  Decision  2009/790/EC2,  Poland  was  authorised,  until  31  December  2012,  to 
exempt from VAT taxable persons whose annual turnover is no higher than the equivalent in 
national  currency of EUR 30 000 at  the conversion  rate on the day of its accession. Poland 
introduced  this  measure  into  national  tax  law  in  two  steps:  from  1  January  2010,  the 
exemption  threshold  was  increased  to  PLN  100  000,  and  from  1  January  2011,  was  further 
raised to PLN 150 000. 

The  authorisation  to  apply  that  special  measure  was  subsequently  extended  by  Council 
Implementing Decision 2012/769/EU3 until 31 December 2015 and by Council Implementing 

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OJ L 347, 11.12.2006, p.1. 
Council Decision of 20 October 2009 authorising the Republic of Poland to apply a measure derogating 
from  Article  287  of  Directive  2006/112/EC  on  the  common  system  of  value  added  tax  (OJ  L  283, 
30.10.2009, p. 53–54). 
Council Implementing Decision of 4 December 2012 amending Decision 2009/790/EC authorising the 
Republic of Poland to apply a  measure  derogating  from  Article 287 of Directive 2006/112/EC on the 
common system of value added tax (OJ L 338, 12.12.2012, p. 27–28). 

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Decision  (EU)  2015/11734  until  31  December  2018.  Council  Implementing  Decision  (EU) 
2016/20905 increased the exemption threshold to the equivalent in national currency of EUR 
40 000. Poland implemented this measure on 1 January 2017 by raising the threshold for VAT 
exemption for small enterprises to PLN 200 000 annual turnover. This scheme is currently in 
force on the basis of Council Implementing Decision (EU) 2018/1919, authorising Poland to 
apply this derogation until 31 December 20216. 

An  authorisation  to  continue  to  use  the  exemption  beyond  2021  for  taxable  persons  whose 
annual turnover is no higher than the equivalent in PLN of EUR 40 000 would be a significant 
simplification for persons operating relatively small businesses. Taxable persons covered by 
this  exemption  do  not  have  to  deduct  and  pay  VAT,  be  registered  for  VAT  or  keep  a  full 
detailed record of transactions subject to VAT. Thanks to these simplifications, small business 
owners  can  devote  more  time  and  resources  to  developing  their  business.  The  derogating 
measure remains voluntary for taxable persons. 

Moreover,  the  cost  of  collecting  VAT  from  taxable  persons  operating  businesses  with 
relatively  low  turnover,  resulting  from  providing  taxpayer  services  to  these  taxable  persons 
and auditing their tax returns, is disproportionately high in comparison to the amount of tax 
collected. Accordingly, by applying a VAT exemption to small business owners, the revenue 
administration  may  direct  more  resources  towards  preventing  and  combating  tax  fraud, 
evasion  and  avoidance,  and  towards  improving  the  quality  of  taxpayer  services  and  the 
effectiveness of collecting VAT from large-scale business operators. 

The  measure  does  not  significantly  affect  the  total  amount  of  revenue  from  VAT  or  the 
overall amount of tax revenue collected at the stage of final consumption. 

The  derogating  measure,  simplifying  the  obligations  of  small  operators,  is  in  line  with  the 
objectives set out by the European Union for small businesses. 

It  is  therefore  appropriate  to  authorise  Poland  to  apply  the  derogating  measure  until  31 
December 2024. 

• 

Consistency with existing policy provisions in the policy area 

The derogating measure is in line with the objectives of Directive (EU) 2020/285 amending 
Articles  281  to  294  of  the  VAT  Directive  on  a  special  scheme  for  small  enterprises,  which 
resulted from the VAT action plan7, and aims to create a modern, simplified scheme for those 
businesses.  In  particular,  it  seeks  to  reduce  VAT  compliance  costs  and  distortions  of 
competition  both  domestically  and  at  EU  level,  reduce  the  negative  impact  of  the  threshold 
effect, and facilitate business compliance as well as monitoring by tax administrations. 

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Council  Implementing  Decision  (EU)  2015/1173  of  14  July  2015  amending  Decision  2009/790/EC 
authorising  the  Republic  of  Poland  to  apply  a  measure  derogating  from  Article  287  of  Directive 
2006/112/EC on the common system of value added tax (OJ L 189, 17.7.2015, p. 36–37). 
Council  Implementing  Decision  (EU)  2016/2090  of  21  November  2016  amending  Decision 
2009/790/EC  authorising  the  Republic  of  Poland  to  apply  a  measure  derogating  from  Article  287  of 
Directive 2006/112/EC on the common system of value added tax (OJ L 324, 30.11.2016, p. 7–8). 
Council Implementing Decision (EU) 2018/1919 of 4 December 2018 amending Decision 2009/790/EC 
authorising  the  Republic  of  Poland  to  apply  a  measure  derogating  from  Article  287  of  Directive 
2006/112/EC on the common system of value added tax (OJ L 311, 7.12.2018, p. 32–33). 
Communication  from  the  Commission  to  the  European  Parliament,  the  Council  and  the  European 
Economic and Social Committee on an action plan on VAT – Towards a single EU VAT area – Time to 
decide COM(2016)148 final. 

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Moreover, the threshold of EUR 40 000 is consistent with Directive (EU) 2020/285, insofar as 
it allows Member States to set the annual turnover threshold required for an exemption from 
VAT at a level no higher than EUR 85 000 (or the equivalent in national currency). 

Similar derogations, exempting from VAT taxable persons whose annual turnover is below a 
certain  threshold,  as  provided for in  Articles  285 and 287 of the VAT  Directive, have been 
granted  to  other  Member  States.  The  Netherlands8  has  been  granted  a  threshold  of  EUR 
25 000;  Italy9  a  threshold  of  EUR  30  000;  Belgium  a  threshold  of  EUR  25  00010, 
Luxembourg11 a threshold of EUR 35 000; Latvia12, Estonia13 have been granted a threshold 
of EUR 40 000; Lithuania14 a threshold of EUR 55 000; Croatia15 a threshold of 45 000 and 
Malta16  a  threshold  of  EUR  20  000;  Hungary17  a  threshold  of  EUR  48  000;  Slovenia18  a 
threshold of EUR 50 000; and Romania19 a threshold of EUR 88 500. 

Derogations from the VAT Directive should always be limited in time so that their effects can 
be  assessed.  In  addition,  the  inclusion  of  an  expiry  date  of  the  special  measure  until  31 

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Council  Implementing  Decision  (EU)  2018/1904  of  4  December  2018  authorising  the  Netherlands  to 
introduce  a  special  measure  derogating  from  Article  285  of  Directive  2006/112/EC  on  the  common 
system of value added tax (OJ L 310, 6.12.2018, p. 25). 
Council  Implementing  Decision  (EU)  2016/1988  of  8  November  2016  amending  Implementing 
Decision  2013/678/EU  authorising  the  Italian  Republic  to  continue  to  apply  a  special  measure 
derogating from Article 285 of Directive 2006/112/EC on the common system of value added tax (OJ L 
306, 15.11.2016, p.11-12). 
Council  Implementing  Decision  (EU)  2018/2077  of  20  December  2018  amending  Implementing 
Decision 2013/53/EU authorising the Kingdom of  Belgium to introduce a special  measure derogating 
from  Article  285  of  Directive  2006/112/EC  on  the  common  system  of  value  added  tax  (OJ  L  331, 
28.12.2018, p. 222–223). 
Council  Implementing  Decision  (EU)  2019/2210  of  19  December  2019  amending  Implementing 
Decision 2013/677/EU authorising Luxembourg to introduce a special measure derogating from Article 
285  of  Directive  2006/112/EC  on  the  common  system  of  value  added  tax  (OJ  L  332,  23.12.2019,  p. 
155). 
Council  Implementing  Decision  (EU)  2020/1261  of  4  September  2020  amending  Implementing 
Decision  (EU)  2017/2408  authorising  the  Republic  of  Latvia  to  apply  a  special  measure  derogating 
from  Article  287  of  Directive  2006/112/EC  on  the  common  system  of  value  added  tax  (OJ  L  296, 
10.9.2020, p. 4–5). 
Council Implementing Decision (EU) 2021/358 of 22 February 2021 amending Implementing Decision 
(EU) 2017/563 authorising the Republic of Estonia to apply a special measure derogating from Article 
287 of Directive 2006/112/EC on the common system of value added tax (OJ L 69, 26.2.2021, p. 4–5). 
Council  Implementing  Decision  (EU)  2021/86  of  22  January  2021  authorising  the  Republic  of 
Lithuania  to  apply  a  special  measure  derogating  from  Article  287  of  Directive  2006/112/EC  on  the 
common system of value added tax (OJ L 30, 28.1.2021, p. 2–3). 
Council  Implementing  Decision  (EU)  2020/1661  of  3  November  2020  amending  Implementing 
Decision (EU) 2017/1768 authorising the Republic of Croatia to introduce a special measure derogating 
from  Article  287  of  Directive  2006/112/EC  on  the  common  system  of  value  added  tax  (OJ  L  374, 
10.11.2020, p. 4–5). 
Council  Implementing  Decision  (EU)  2021/753  of  6  May  2021  authorising  Malta  to  apply  a  special 
measure derogating from Article 287 of Directive 2006/112/EC on the common system of value added 
tax, and repealing Implementing Decision (EU) 2018/279 (OJ L 163, 10.5.2021, p. 1–2). 
Council Implementing Decision (EU) 2018/1490 of 2 October 2018 authorising Hungary to introduce a 
special measure derogating from Article 287 of Directive 2006/112/EC on the common system of value 
added tax (OJ L 252, 8.10.2018, p.38). 
Council  Implementing  Decision  (EU)  2018/1700  of  6  November  2018  amending  Implementing 
Decision  2013/54/EU  authorising  the  Republic  of  Slovenia  to  introduce  a  special  measure  derogating 
from  Article  287  of  Directive  2006/112/EC  on  the  common  system  of  value  added  tax  (OJ  L  285, 
13.11.2018, p. 78). 
Council  Implementing  Decision  (EU)  2020/1260  of  4  September  2020  amending  Implementing 
Decision (EU) 2017/1855 authorising Romania to apply a special measure derogating from Article 287 
of Directive 2006/112/EC on the common system of value added tax (OJ L 296, 10.9.2020, p. 1–3). 

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December 2024, as requested by Poland, is aligned with the requirements of Directive (EU) 
2020/285  on  simpler  VAT  rules  for  small  and  medium-sized  enterprises.  That  directive 
provides  for  1  January  2025  as  the  date  on  which  Member  States  will  have  to  apply  the 
national provisions, which they are required to adopt, to comply with it. 

The proposed measure is therefore consistent with the provisions of the VAT Directive. 

• 

Consistency with other Union policies 

The  Commission  has  been  consistently  stressing  the  need  for  simpler  rules  for  small 
enterprises.  In  this  respect,  the  Commission  adopted  in  March  2020  an  SME  Strategy  for  a 
sustainable and digital Europe20, where it committed to continue to work to reduce the burden 
on SMEs. The objective to reduce the regulatory burden for SMEs is one of the pillars of that 
strategy.  This  special  measure  is  in  line  with  such  objectives,  as  far  as  fiscal  rules  are 
concerned.  It  is  also  consistent  with  the  2020  Action  Plan  on  fair  and  simple  taxation 
supporting  the  recovery  strategy21,  which  acknowledges  that  tax  compliance  costs  remain 
high in the EU, and that compliance costs are typically substantially higher for small than for 
large companies. 

2. 

• 

LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY 

Legal basis 

Article 395 of the VAT Directive. 

• 

Subsidiarity (for non-exclusive competence)  

Considering the provision of the VAT Directive on which it is based, the proposal falls under 
the exclusive competence of the European Union. Hence, the subsidiarity principle does not 
apply. 

• 

Proportionality 

The Decision concerns an authorisation granted to a Member State upon its own request and 
does not constitute any obligation. 

Given  the  limited  scope  of  the  derogation,  the  special  measure  is  proportionate  to  the  aim 
pursued,  i.e.  to  simplify  the  tax  collection  for  small  taxable  persons  and  for  the  tax 
administration. 

• 

Choice of the instrument 

The instrument proposed is a Council Implementing Decision. 

Under Article 395 of the VAT Directive, a derogation from the common VAT rules is only 
possible upon authorisation by the Council, which is acting unanimously on a proposal from 
the  Commission.  A  Council  Implementing  Decision  is  the  most  suitable  instrument  since  it 
can be addressed to an individual Member State. 

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COM(2020) 103 final. 
COM(2020) 312 final. 

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3. 

• 

RESULTS 
CONSULTATIONS AND IMPACT ASSESSMENTS 

EX-POST 

EVALUATIONS, 

OF 

STAKEHOLDER 

Stakeholder consultations 

No stakeholder consultation has been conducted. The present proposal is based on a request 
made by Poland and concerns only this particular Member State. 

• 

Impact assessment 

The  proposal  for  a  Council  Implementing  Decision  applying  threshold  of  annual  turnover 
below  which  taxable  persons  may  be  exempted  from  VAT  prolongs  the  simplification 
measure which removes many of the VAT obligations for businesses operating with an annual 
turnover no higher than EUR 40 000.  

Persons whose taxable turnover does not exceed the threshold will not have to register to be 
identified  for  VAT  purposes,  and  thus  the  administrative  burden  on  them  will  reduce  as  a 
result of the measure, since they will not need to keep VAT records or submit a VAT return. 
There  will  also  be  a  reduction  in  the  workload  for  the  tax  authorities.  This  will  have  a 
potential  positive  impact  on  the  reduction  of  administrative  burden  for  taxable  persons 
currently registered for VAT in Poland, and subsequently on the tax administration.  

According to Poland, at 31 December 2019, 4 014 354 companies (excluding natural persons 
operating  individual  agricultural  holdings  only)  were  registered  in  the  National  Official 
Business Register (REGON). Poland’s population at the time was 38 382 576. 

The number of companies which declared that they were operating a business with anticipated 
staff numbers of up to nine persons was 3 853 900. This accounts for 96% of all companies. 
The data clearly confirms that micro-entities predominate in Poland.  

The  estimated  annual  impact  of  the  continued  application  of  the  increased  exemption 
threshold in the amount of PLN equivalent of EUR 10 000 provided for in Article 287, point 
(14), of Directive 2006/112/EC to EUR 40 000, if all entitled taxable persons made use of this 
voluntary exemption, would amount to approximately PLN 1.6 billion, which corresponds to 
approximately  0.9%  of  the  state  budget  revenue  from  VAT  in  2019.  We  would  like  to 
highlight  that  Poland has been applying the higher exemption  threshold for over 10  years  – 
from 1 January 2017 in the amount of PLN equivalent of EUR 40 000 (PLN 200 000). 

According to  the data available for 2019, the  VAT exemption  would cover around 300 694 
taxable  persons  whose  turnover  falls  between  EUR  10  000  and  EUR  40  000.  The  effect  is 
negligible. 

• 

Fundamental rights 

The proposal does not have any consequences for the protection of fundamental rights  

4. 

BUDGETARY IMPLICATIONS 

Following  entering  into  force  of  Council  Regulation  (EU,  Euratom)  2021/769  of  30  April 
2021  amending  Regulation  (EEC,  Euratom)  No  1553/89  on  the  definitive  uniform 
arrangements for the collection of own resources accruing from value added tax22, there will 

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Council  Regulation (EU, Euratom) 2021/769 of 30 April  2021 amending Regulation (EEC, Euratom) 
No 1553/89 on the definitive uniform arrangements for the collection of own resources accruing from 
value added tax (OJ L 165, 11.5.2021, p. 9–14). 

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be no compensation calculation carried out by Poland as of VAT own resource statement for 
the financial year 2021 onwards. 

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2021/0252 (NLE) 

Proposal for a 

COUNCIL IMPLEMENTING DECISION 

amending Decision 2009/790/EC authorising the Republic of Poland to apply a measure 
derogating from Article 287 of Directive 2006/112/EC on the common system of value 
added tax 

THE COUNCIL OF THE EUROPEAN UNION, 

Having regard to the Treaty on the Functioning of the European Union,  

Having  regard  to  Council  Directive  2006/112/EC  of  28  November  2006  on  the  common 
system of value added tax1, and in particular of Article 395(1), first subparagraph, thereof, 

Having regard to the proposal from the European Commission, 

Whereas: 

(1) 

(2) 

(3) 

(4) 

(5) 

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Pursuant  to  Article  287  point  (14),  of  Directive  2006/112/EC,  Poland  may  exempt 
from value added tax (VAT) taxable persons whose annual turnover is no higher than 
the equivalent in national currency of EUR 10 000 at the conversion rate on the day of 
its accession. 
Council  Decision  2009/790/EC2  authorises  Poland  to  introduce  a  special  measure 
derogating from Article 287 of Directive 2006/112/EC  to exempt from VAT taxable 
persons whose annual turnover is no higher than the equivalent in national currency of 
EUR 40 000 (‘the derogating measure’). 
By  Council  Implementing  Decision  (EU)  2018/19193,  Poland  was  authorised  to 
continue applying the derogating measure until  31 December 2021 or until the entry 
into force of a directive amending the provisions of Articles 281 to 294 of Directive 
2006/112/EC, whichever date is earlier. 
By  letter  of  1st  March  2021,  Poland  submitted  a  request  to  the  Commission  for  an 
authorisation  to  continue  to  apply  the  derogating  measure  [consisting  in  granting  a 
VAT  exemption  to  taxable  persons  whose  annual  turnover  is  no  higher  than  the 
equivalent in national currency of EUR 40 000] until 31 December 2024. 

In  accordance  with  Article  395(2)  of  Directive  2006/112/EC,  the  Commission 
informed the other Member States, except Cyprus, by letter dated 25 March 2021, and 
Cyprus  by  letter  dated  26  March  2021,  of  the  request  made  by  Poland.  The 
Commission  notified  Poland  by  letter  dated  29  March  2021  that  it  had  all  the 
information necessary to consider the request. 

OJ L 347, 11.12.2006, p. 1. 
Council  Decision  2009/790/EC  of  20  October  2009  authorising  the  Republic  of  Poland  to  apply  a 
measure derogating from Article 287 of Directive 2006/112/EC on the common system of value added 
tax (OJ L 283, 30.10.2009, p. 53–54). 
Council Implementing Decision (EU) 2018/1919 of 4 December 2018 amending Decision 2009/790/EC 
authorising  the  Republic  of  Poland  to  apply  a  measure  derogating  from  Article  287  of  Directive 
2006/112/EC on the common system of value added tax (OJ L 311, 7.12.2018, p. 32). 

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(6) 

(7) 

(8) 

(9) 

The derogating measure is in line with the objectives of Commission Communication 
"Think small first" – a "Small Business Act" for Europe4. 

Based  on  information  provided  by  Poland,  the  derogating  measure  will  only  have  a 
negligible impact on the overall amount of tax revenue of Poland collected at the stage 
of final consumption. Taxable persons may still opt for the normal VAT arrangements.  

Following  entering  into  force  of  Council  Regulation  (EU,  Euratom)  2021/769  of  30 
April  2021  amending  Regulation  (EEC,  Euratom)  No  1553/89  on  the  definitive 
uniform arrangements for the collection of own resources accruing from value added 
tax5, there will be no compensation calculation carried out by Poland as of VAT own 
resource statement for the financial year 2021 onwards. 

Given  the  potential  positive  impact  of  the  derogating  measure  in  reducing  the 
administrative burden and costs for small businesses, Poland should be authorised to 
apply the derogating measure for a further period.  

(10)  Council  Directive  (EU)  2020/2856  amended  Articles  281  to  294  of  Directive 
2006/112/EC as regards the special scheme for small enterprises and laying down new 
rules for small enterprises, including the maximum threshold of Member State annual 
turnover of EUR 85 000 or the equivalent in national currency. 

(11)  The authorisation to apply the derogating measure should be limited in time. The time 
limit  should  be  sufficient  to  allow  the  effectiveness  and  appropriateness  of  the 
threshold to be evaluated. Moreover, according to Directive (EU) 2020/285, Member 
States  are  to  adopt  and  publish,  by  31  December  2024,  the  laws,  regulations  and 
administrative  provisions  necessary  to  comply  with  Article  1  of  that  Directive,  and 
apply  those  provisions  from  1  January  2025.  It  is  therefore  appropriate  to  authorise 
Poland to apply the derogating measure until 31 December 2024. 

(12)  Decision 2009/790/EC should therefore be amended accordingly.  

HAS ADOPTED THIS DECISION:  

Article 1 

Article 2 of Decision 2009/790/EC is replaced by the following: 

“Article 2 

This Decision shall apply from 1 January 2010 until 31 December 2024.”  

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Communication  from  the  Commission  to  the  Council,  the  European  Parliament,  the  European 
Economic and Social Committee and the Committee of the Regions  - “Think Small First” - A “Small 
Business Act” for Europe, Brussels, 25.6.2008, COM(2008)394 final.  
Council  Regulation (EU, Euratom) 2021/769 of 30 April  2021 amending Regulation (EEC, Euratom) 
No 1553/89 on the definitive uniform arrangements for the collection of own resources accruing from 
value added tax (OJ L 165, 11.5.2021, p. 9–14). 
Council  Directive  (EU)  2020/285  of  18  February  2020  amending  Directive  2006/112/EC  on  the 
common system of value added tax as regards the special scheme for small enterprises and Regulation 
(EU)  No  904/2010  as  regards  the  administrative  cooperation  and  exchange  of  information  for  the 
purpose  of  monitoring  the  correct  application  of  the  special  scheme  for  small  enterprises  (OJ  L  62, 
2.3.2020, p. 13–23). 

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This Decision is addressed to the Republic of Poland. 

Done at Brussels, 

Article 2 

For the Council 
The President 

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