Overview
GTU (from the Polish "grupa towarów i usług", meaning group of goods and services) is a set of 13 markers that the Polish tax administration uses to flag specific high-risk goods and services on an invoice. In the FA(3) XML, GTU lives on each invoice line at /Faktura/Fa/FaWiersz/GTU, and on order lines at /Faktura/Fa/Zamowienie/ZamowienieWiersz/GTUZ.
The key rule: GTU is only required when the item you sell falls into one of the 13 closed categories below. A plain SaaS subscription, a consulting retainer, or a design project typically does not carry any GTU code, because those services are not on the list.
The 13 GTU codes are:
- GTU_01 — alcoholic beverages above 1.2% ABV, beer, and beer-and-non-alcoholic mixes above 0.5% (CN 2203–2208).
- GTU_02 — goods under Art. 103 sec. 5aa of the VAT Act.
- GTU_03 — fuel oils, lubricating oils and lubricating preparations (specific CN codes).
- GTU_04 — tobacco products, dried tobacco, e-cigarette liquids and novelty products.
- GTU_05 — waste, only as listed in items 79–91 of Annex 15.
- GTU_06 — electronic devices and their parts and materials, only as listed in Annex 15 items 7, 8, 59–63, 65, 66, 69 and 94–96, plus stretch film (item 9).
- GTU_07 — vehicles and parts (CN 8701–8708).
- GTU_08 — precious and base metals, only as listed in Annex 12 items 1 and 1a and Annex 15 items 12–25, 33–40, 45, 46, 56 and 78.
- GTU_09 — medicinal products, food for particular nutritional uses and medical devices subject to the Art. 37av notification duty.
- GTU_10 — buildings, structures and land, and parts or interests in them.
- GTU_11 — transfer of greenhouse-gas emission allowances.
- GTU_12 — intangible services, only the closed PKWiU list (consulting, accounting/audit, legal, management, marketing/advertising, market research, R&D, non-school education).
- GTU_13 — transport and warehouse management services (PKWiU 49.4, 52.1).
GTU is about what you sell, not how it is taxed. It is separate from the VAT rate (P_12), from the procedure marking (Procedura, e.g. WSTO_EE or IED) and from the invoice annotations (Adnotacje, e.g. split payment P_18A). A single line can carry a GTU code and a VAT rate at the same time.
Several GTU codes depend on the CN or PKWiU classification of the product or service. If you are not certain whether your item falls into a category — for example whether your software-related service matches the closed PKWiU list of GTU_12 — confirm with a qualified accountant rather than guessing. Classifying a good or service into a specific CN/PKWiU code is a legal question, not a formatting question.
In Notaly you set the GTU code per line item when you send the invoice, and it is written to the FA(3) XML. If you are not sure a code applies, leave it out: for most digital and SaaS businesses, no GTU code is needed.
Notaly is not a tax, accounting or legal advisor. This article is general information, not tax advice, and may be outdated. You are responsible for your own VAT compliance; confirm with a qualified accountant where required.
Sources
- https://crd.gov.pl/wzor/2025/06/25/13775/
- https://ksef.podatki.gov.pl/media/f2hnwjk2/information-sheet-on-the-fa-3-logical-structure.pdf
Source: crd.gov.pl