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SLIM VAT 3 – chain transactions

Another of the changes proposed as part of the SLIM VAT 3 package, amending the VAT Law, concerns chain transactions. This is the third change to intra-Community transactions that has been proposed in the draft law in addition to ICA and ICS itself, which we wrote about on our blog.

Chain transactions

Chain transactions are those in which the same goods are the subject of subsequent supply and are directly shipped or transported from the first supplier to the last in line purchaser. Then, according to Article 22(2), the shipment or transportation is assigned to only one supply.

In the case of chain transactions, one of the key aspects is therefore the issue of proper attribution of transportation. Depending on the appropriate recognition of the intermediary entity, the type of identification number provided, and which entity in the chain is shipping/transporting the goods in question – it may be different to attribute the supply or transportation to the corresponding supply in turn.

Recognized supplier regime

Introduced with the VAT e-commerce package, the deemed supplier regime (to which Article 7a of the VAT Law refers) stipulates that where a taxpayer facilitates, through the use of an electronic interface such as a platform, trading platform, portal or similar means (“electronic interface”), the remote sale of imported goods in consignments with an actual value not exceeding the equivalent of €150 expressed in PLN, the taxpayer shall be deemed to have independently received the goods and made the supply.

Moreover, where a taxpayer facilitates, through the use of an electronic interface, the making of an intra-Community sale of goods in the territory of the European Union by a non-established taxpayer or a fixed place of business in the territory of the European Union:

  • a distance intra-Community sale of goods, or
  • the supply of goods to a non-taxpayer

– the taxpayer who facilitates this supply is deemed to have independently received the goods and made the supply.

What will change?

According to the above Article 7a, a special allocation rule applies to transactions using an electronic interface. The shipment or transportation of goods is allocated to a supply made by a taxpayer who facilitates the supply of goods through the use of an electronic interface (such as an e-commerce trading platform).

Therefore, the above-described provisions of Article 22 (2-2d) regarding the allocation of transportation in chain supplies do not apply to such transactions. The amendment, according to which paragraph 2e, i.e. the method of allocating the shipment depending on the entity organizing it, will also not be included in them, is therefore rather only clarifying , but should nevertheless be evaluated positively due to the fact that it will clearly negate possible divagations about the appropriate method of accounting for the type of transaction in question.


Currently, the draft law is at the stage of the Public Finance Committee’s report after the first reading at the Sejm, and the legislative process can be followed -> here <-. According to the latest version of the law dated 30 March 2023, the entry into force of the new wording of the law with regard to most provisions has been postponed again from 1 April 2023 to 1 July 2023.