Freelancing keeps getting more lucrative: there’s nothing stopping you from taking on clients in any country. Naturally, many freelancers wonder whether income from foreign contracts requires registering a business, and how to report it, especially when the client is in the US, UK, or an EU country. This is a particularly relevant topic for B2B contractors, since “one foreign client, regular pay” is also one of the risk factors for reclassification under the PIP 2026 reform, covered in our PIP 2026 guide for B2B contractors.

The contract with your foreign client

Start by working out whether your agreement with a foreign client corresponds to a specific-task contract (umowa o dzieło), a mandate contract (umowa zlecenie), or a B2B contract. Polish law has no such thing as a generic “cooperation agreement with a foreign employer,” so ask yourself which type of contract you’d sign if you were providing the same services to a Polish company.

We cover the different freelancer contract types in more detail in Freelancer Accounting in Poland: What You Need to Know.

Mandate and specific-task contracts count as personal activity (when signed with a business entity), so you don’t need to register a JDG, though you can. If a freelancer’s task would, in Poland, require a specific-task contract transferring copyright, the earnings are classified as income from property rights. If the nature of a contract is ambiguous (e.g., it mixes agency and mandate elements), it’s classified as “other sources.”

Do you need to register a business?

Under the Personal Income Tax Act¹, income can come from several sources: business activity, personal activity, income from property rights, or other sources.

¹Act of July 26, 1991, on Personal Income Tax.

Business activity is just one of those options. If a freelancer’s income is classified under a source other than business activity, there’s no obligation to register a JDG, regardless of how much that income adds up to. The obligation to register a JDG kicks in when the income-generating activity becomes continuous and organized, regardless of how many clients you serve or whether they’re domestic or foreign.

Unlimited tax liability: worldwide income

This is the single most important rule in this article: freelancers who are Polish tax residents are subject to unlimited tax liability: they must declare all their income, from any source and country, on their Polish tax return. It doesn’t matter whether the client is in the US, UK, Hong Kong, or an EU member state.

You’re a Polish tax resident if you meet either of two conditions: your center of personal or economic interests is in Poland, or you’re physically present in Poland for at least 183 days in the given tax year.

How the tax is calculated depends on which income source your earnings fall under. Because this income usually comes from abroad without a withholding payer (a foreign business isn’t a payer in Poland), the freelancer is responsible for calculating and remitting their own PIT advances.

This mainly applies to specific-task contracts (without copyright transfer) and mandate contracts with a foreign client. If you have a large number of such contracts, you can apply the standard lump-sum cost deduction.

The forms you need:

  • PIT-36 with attachment PIT/ZG: for income received without a withholding payer (the foreign client didn’t withhold an advance); if you also run a business, attach PIT/B as well;
  • PIT-37: if you worked exclusively with Polish companies that issued you a PIT-11;
  • PIT-36: if part of your income is from Poland and part from abroad without a withholding payer.

On ZUS contributions: under a specific-task contract (with or without copyright transfer), there’s no obligation to pay social security contributions on foreign income. Other forms of cooperation are more complicated: a foreign company with no Polish presence should, in theory, obtain a NIP and start paying contributions, though in practice ZUS has limited means of enforcing this against entities outside the EU.

Double taxation avoidance agreements

Declaring your full income in Poland doesn’t mean the same income gets taxed twice. Poland has double taxation avoidance agreements (DTAs) with most countries, including the US and the UK. Each treaty specifies one of two methods:

  • exemption with progression: the foreign income is exempt from Polish tax but still affects the tax rate (progression) applied to your Polish income;
  • proportional deduction (tax credit): the foreign income is taxed in Poland, but tax already paid abroad can be credited (up to the amount of Polish tax attributable to that income).

Which method applies depends on the specific treaty with the client’s country, so you need to check the text of the treaty relevant to your client’s country. For most B2B services provided remotely from Poland (with no foreign “permanent establishment”), the income is taxed in Poland, and any foreign withholding tax is credited according to the method set out in the relevant DTA.

Converting foreign currency income

Income received in a foreign currency is converted to PLN using the average NBP exchange rate from the last business day preceding the day the income arises (the day it becomes due or is actually received, depending on your tax method). The same “preceding day” logic applies for VAT purposes (see below), except that for VAT what counts is the day the tax obligation arises, or the invoice date if earlier.

The CFR-1 tax residency certificate

If a foreign client (especially in the US) asks for a document confirming your Polish tax residency before paying you, that’s the CFR-1 tax residency certificate. Without it, the foreign payer may apply its domestic withholding tax rate (in the US, sometimes as high as 30% by default on certain categories of non-resident income); with the certificate and the relevant local form (e.g., W-8BEN for the US), a reduced treaty rate or a full exemption may apply instead.

We cover the application process, costs, and issuance timelines for CFR-1 in a separate article: What Is a Tax Residency Certificate (CFR-1) in Poland?. Important: your JDG’s tax method (scale, flat tax, ryczałt) has no bearing on whether you need a CFR-1, since the need for the certificate comes purely from working with a foreign payer.

VAT on services for US and EU clients

For freelancers running a JDG and providing B2B services (e.g., IT, consulting, translation), the key rule is the place of supply for services (Art. 28b of the VAT Act): for B2B services, the taxable place is the country where the service recipient (client) is established, not Poland.

In practice:

  • A client in the US (outside the EU): the service isn’t subject to Polish VAT. Invoice without VAT, marked “NP” (not applicable) and “reverse charge.” The sale is reported in the JPK_V7 as a sale outside Polish territory. No VAT-EU summary is filed (that only applies to intra-EU transactions).
  • A client in the EU who’s a VAT taxpayer: the service also isn’t subject to Polish VAT. Invoice without VAT, marked “reverse charge,” meaning the buyer accounts for VAT in their own country. You need to be registered for VAT-EU (form VAT-R), even if you’re VAT-exempt in Poland, and report the transaction in the VAT-EU summary information by the 25th of the month following the month the tax obligation arose. It’s worth verifying the client’s VAT number through VIES.

2026 update: from April 1, 2026, the National e-Invoicing System (KSeF) becomes mandatory for all VAT-paying JDGs in Poland. That includes invoices for foreign clients too, though this doesn’t technically change the VAT/PIT rules described above.

A B2B freelancer who works regularly for a single foreign client, on that client’s schedule and with that client’s tools, can fit the reclassification risk profile under the PIP 2026 reform, regardless of the client being based outside Poland. The reform applies to any civil-law or B2B contract that shows signs of subordination, no matter where the client is headquartered. More in our [PIP 2026 guide for B2B contractors](https://mojafirma.org/pip-2026-b2b-poland-guide/).

Different ways to find foreign clients

Freelancers land foreign clients by pitching businesses directly, responding to job posts, and increasingly through specialized platforms that also handle payments:

  • Upwork
  • Fiverr
  • Freelancer.com
  • Toptal

The most common work found this way is programming, web design, translation, and server management. Foreign contracts tend to be very lucrative, and, the formalities above notwithstanding, settling them isn’t as complicated as it might first appear.

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FAQ

Do I have to pay Polish VAT on services provided to a US client? No, for B2B services, the taxable place is the client’s country, so a service for a US client isn’t subject to Polish VAT. You invoice without VAT, marked “NP”/”reverse charge.”

Do I need to register for VAT-EU if I’m VAT-exempt in Poland? Yes, if you provide B2B services to VAT-registered businesses in other EU countries, VAT-EU registration (VAT-R) is required regardless of your VAT exemption status in Poland.

Which double-taxation method applies to a contract with a US client? It depends on the specific provisions of the US-Poland DTA and the type of income involved: for typical B2B services delivered remotely from Poland, the income is usually taxed in Poland, with a credit for tax actually paid in the US. The exact method for specific income categories can vary by service type, so it’s worth verifying your individual case with an accountant or tax advisor.

Bibliography and Legal Basis

  • Act of July 26, 1991, on Personal Income Tax, Art. 3 (unlimited tax liability) (Journal of Laws 1991, No. 80, item 350, consolidated text)
  • Act of March 11, 2004, on Tax on Goods and Services, Art. 28b (place of supply for B2B services) and Art. 31a (exchange rate for VAT) (Journal of Laws 2004, No. 54, item 535, consolidated text)
  • Double taxation avoidance agreements: full list on podatki.gov.pl (including with the US and the UK)

Author: MojaFirma team.

This article is for informational purposes only and does not constitute legal advice. Every situation depends on the specific contract and individual circumstances. If something about your own situation isn’t quite clear, feel free to book a free consultation with our team.