Short-term rental and VAT: when do you have to register?

A reassuring belief circulates among nightly rental hosts: "as long as I stay under 240 thousand in turnover, VAT does not apply to me". Unfortunately that is a half-truth, and it can be expensive. In short-term rental there are two completely different situations in which VAT appears, and only one of them depends on the turnover threshold. This article takes both apart.

The short answer

• Registration as an active VAT payer becomes mandatory only once you exceed PLN 240,000 in annual turnover. From that point you apply the 8% rate to accommodation services.
• EU VAT registration and settling the import of services can apply to you from the very first booking if you pay commission to Booking or Airbnb. This is independent of the 240,000 threshold and applies even when you are not an active VAT payer.

In other words: the PLN 240,000 threshold decides VAT on your sales, but it does not release you from VAT on the commissions charged by foreign platforms. Those are two separate matters.

The PLN 240,000 threshold: the subject-based VAT exemption

The basis is the so-called subject-based exemption (Article 113(1) of the VAT Act). It exempts from VAT those taxpayers whose sales value in the previous year did not exceed PLN 240,000 (net of tax). In practice that covers most owners renting out one or two flats.

As long as you are below the threshold:

• you do not charge VAT on stays,
• you do not file JPK_V7 for your own sales,
• you do not register as an active VAT payer.

The threshold is counted cumulatively over the year. The moment you cross it, the exemption disappears and the obligation to register arises.

Above the threshold: registration and the 8% rate

Once turnover exceeds PLN 240,000, VAT registration is mandatory (form VAT-R, before the day you cross the threshold). From then on:

• short-term rental as an accommodation service (PKWiU 55) is covered by the preferential 8% rate,
• you can deduct VAT on purchases related to the business,
• you file JPK_V7 files and settle VAT periodically.

One important distinction is worth remembering: short-term rental is an accommodation service, not "ordinary" residential letting. Long-term letting for residential purposes (over 30 days) benefits from the object-based exemption (Article 43(1)(36)). For nightly rental that exemption does not apply.

The trap almost nobody mentions: import of services from Booking and Airbnb

This is the most frequently overlooked obligation. Platforms such as Booking and Airbnb are established outside Poland (in Ireland or the Netherlands, for example). The commission they deduct is, from a VAT point of view, an import of services, and the tax on it is settled by you, the buyer.

The key point: the subject-based exemption (that 240 thousand) does not cover the import of services. This means that even if you are below the threshold and are not an active VAT payer, you are obliged to:

• register for EU VAT (registration for intra-Community transactions, form VAT-R, the VAT-EU section),
• settle the output VAT on the commission (usually 23% of the commission amount),
• report it in the VAT-9M return and pay the tax (if you do not file JPK_V7).

Two pieces of good news to soften it:

• settling the import of services does not cost you the subject-based exemption from VAT on your own sales,
• using the portals does not force you to reclassify private letting as a business activity.

This is exactly where arrears most often arise. In 2026, with platforms reporting data under DAC7 and the tax authority's systems analysing it automatically, an unreported import of services is easy to spot.

What about a cash register?

If you provide accommodation services to private individuals, as a rule you need a fiscal cash register and must issue receipts. There is, however, an important exemption: if the entire payment goes to a bank account (transfer, card, via a bank or credit union) and the documentation clearly shows what the transaction covered, you can be exempt from the register.

Watch out for the catch: if a guest pays you anything in cash directly (a surcharge on arrival, say), the exemption may stop applying. The cash register conditions are conditional, so check the current regulation and its exclusions before you start.

KSeF and e-invoices in 2026

The mandatory National e-Invoicing System is being phased in during 2026. Invoices for consumers (guests) do not have to be issued in KSeF, but if you invoice companies or are an active VAT payer, check from what date the obligation covers your situation.

Frequently asked questions

I am below PLN 240,000. Does VAT concern me at all?

Not on your sales. But it does concern the commission from Booking and Airbnb: that is an import of services, which you settle regardless of the threshold.

Does settling commission mean I lose the VAT exemption?

No. Import of services does not remove the subject-based exemption on your own sales.

What VAT rate applies to nightly rental above the threshold?

8%, because this is an accommodation service (PKWiU 55), not exempt residential letting.

Do I need a cash register?

Not always. With cashless payments only and complete records you can use the exemption, but cash from guests can block it.

Does using Airbnb automatically make me a business?

No. Simply using a platform does not settle the question of business activity. What counts is the scale and character of the letting.

This article is informational and reflects the state of play in 2026. It is not tax advice. Regulations, interpretations and thresholds can change, and your situation may require individual analysis. Before registering for VAT or settling an import of services, consult an accountant or tax adviser.