Foreign-Currency Invoices in KSeF – Position of the Head of the Polish Tax Authority

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Invoices issued in foreign currencies have long been one of the more complex areas of VAT settlements. With the upcoming mandatory implementation of the National e-Invoicing System (KSeF), this issue has gained even greater importance. Businesses want to be certain how to correctly determine the invoice issue date and the exchange rate used to convert the taxable base for VAT purposes—especially when an invoice is submitted to KSeF on a different date than the one indicated on the document itself.

These exact questions were addressed in an individual tax ruling issued by the Krajowa Informacja Skarbowa.

Background of the case

The applicant was a company with its registered office and permanent establishment in Poland, subject to unlimited tax liability. The company operates in the sale of chemical raw materials on both domestic and foreign markets and also provides comprehensive logistics services.

Invoices are issued in accordance with an internal invoicing policy, with the invoice date corresponding to the moment when the VAT tax obligation arises—i.e. the delivery date. However, in the case of intra-Community supplies and exports, confirmation documents from carriers may be received with a delay of several days. As a result, invoices may be issued after the delivery date, but still indicate the correct tax point.

KSeF and different invoice dates

As part of preparations for KSeF implementation, the company plans to issue invoices in its internal system and then submit them to KSeF via an interface application. In practice, this may result in three different dates:

• the date indicated in field P_1 of the structured invoice (invoice issue date),

• the date the invoice is generated in the system,

• the date the invoice is sent to KSeF.

This raised doubts as to which date should be considered decisive for VAT purposes and for determining the exchange rate for foreign-currency invoices.

Position of the taxpayer

The company argued that:

• if an invoice is submitted to KSeF after the date indicated in field P_1, the invoice issue date remains the date shown in P_1, not the date of submission to KSeF;

• consequently, foreign-currency amounts should be converted using the average exchange rate published by the National Bank of Poland (NBP) on the business day preceding the date on which the VAT obligation arises, i.e. the date shown in field P_1.

  
  

Position of the tax authority

The Head of the Polish tax authority fully agreed with this reasoning. According to the authority:

• if the invoice is submitted to KSeF later than the date indicated on the invoice, it is treated as an offline24 invoice,

• the invoice issue date is the date indicated by the taxpayer on the invoice, not the date of submission to KSeF,

• therefore, the correct exchange rate is the NBP average rate from the last business day preceding the VAT tax point.

  
  

Practical implications for businesses

Important: when issuing foreign-currency invoices under KSeF, the decisive factor for VAT conversion purposes is the date indicated in field P_1 of the structured invoice—not the technical submission date to KSeF.

This interpretation provides much-needed certainty for companies engaged in exports and intra-EU supplies and allows them to maintain existing currency conversion practices, provided invoice dates are correctly determined.

Legal basis

Individual tax ruling issued by the Head of the Polish National Tax Information on 3 December 2025, reference no. 0112-KDIL1-3.4012.760.2025.1.MR