In recent years, thousands of Ukrainians have moved to Poland but continue operating as FOP (sole proprietors) in Ukraine. At the same time, an increasingly common question arises: is it worth switching to JDG — the Polish equivalent of a sole proprietorship, and what are the real differences between these systems?
This issue has become especially relevant amid potential changes in Ukrainian legislation, including discussions about VAT for FOPs with higher turnover, as well as increased control over foreign income.
Tell us about your income, clients, and country of residence — we will advise which system is more beneficial specifically for you.
Ukrainian FOP vs Polish JDG: what is the fundamental difference?
At first glance, a Ukrainian FOP and a Polish JDG look similar: one individual, one business, simplified taxation. But in practice, these are two completely different philosophies.
- FOP in Ukraine — максимально simplified format with minimal reporting;
- JDG in Poland — a fully-fledged European business with strict accounting rules.
Business registration: Ukraine vs Poland
FOP in Ukraine
- online registration within 1 day;
- minimal documentation;
- almost zero startup cost;
- often no accountant required.
JDG in Poland
- registration through CEIDG;
- selection of PKD codes (business activity classifications);
- registration with ZUS and the tax office;
- opening a bank account;
- mandatory accounting.
Taxes: simplified systems in Ukraine and Poland
Taxes for FOP in Ukraine
For most IT and service-based FOPs:
- single tax (2–5%);
- fixed social contribution (SSC);
- minimal reporting.
Even with high income, the tax burden remains predictable.
Taxes for JDG in Poland
Poland offers several taxation regimes, but the most popular is Ryczałt (lump-sum tax).
Income tax rates:
- from 2% to 17%, depending on the type of activity;
- different rates for different income types;
- each income must be properly documented.
If the tax office cannot determine which rate applies, the maximum rate may be imposed.
Accounting: where is it simpler?
This is where the difference is most noticeable.
- FOP in Ukraine — often operates without an accountant;
- JDG in Poland — an accountant is practically mandatory.
In Poland, you must:
- maintain income records;
- keep all invoices;
- submit monthly or quarterly reports;
- manage VAT and ZUS contributions.
VAT: a key difference
In Ukraine, most FOPs do not deal with VAT at all.
In Poland:
- VAT registration is required after exceeding a turnover threshold;
- VAT is mandatory when working with EU clients;
- OSS applies for B2C sales;
- VAT status of counterparties must be verified.
ZUS vs SSC: social contributions
SSC in Ukraine
- fixed payment;
- independent of income;
- relatively low burden.
ZUS in Poland
ZUS includes:
- pension insurance;
- health insurance;
- sickness insurance;
- other social funds.
The health contribution depends on income, while social contributions are fixed but significantly higher than in Ukraine.
When is JDG the right decision?
JDG makes sense if:
- you actually reside in Poland;
- you earn income within the EU;
- you plan to legalize your stay through business;
- you are ready to operate fully officially and transparently.
If you live in Ukraine or are only testing the market, a Ukrainian FOP often remains more выгодным.
Conclusion: what should you choose?
A Ukrainian FOP — simpler and cheaper.
A Polish JDG — more complex, but it opens access to:
- legalization in the EU;
- a residence card;
- long-term stability.
The VisaV.pl team helps not just to register a JDG, but to build the right model: business + accounting + legalization.
We will analyze your situation and offer the optimal turnkey solution.
