Belgium has begun enforcement proceedings against Poland, demanding almost 200 million złoty in additional fees and taxes related to the recent court ruling on unpaid COVID-19 vaccines. The move adds a new layer to the already contentious dispute over the 5.65 billion złoty judgment.
The Belgian tax authorities are seeking 170 million złoty – a 3% registration tax on the amount awarded to Pfizer and BioNTech by the Brussels court in April. Together with enforcement costs and administrative fees, the total claim reaches nearly 200 million złoty, according to the Polish health ministry.
Poland has refused to pay the additional sum and has sent a diplomatic note to Belgian authorities asking for clarification on whether the tax applies in disputes involving EU member states. So far, no response has been received.
Background of the dispute
The original court ruling, issued on 1 April 2026 by the French-speaking Court of First Instance in Brussels, ordered Poland to pay approximately 1.3 billion euro (5.65 billion złoty) for 60 million doses of COVID-19 vaccines that were ordered but never collected. The court rejected Poland’s argument that the Russian invasion of Ukraine constituted a force majeure justifying cancellation of the contract.
Poland announced it would appeal the ruling and seek to use all available legal remedies. The health ministry stated that further steps would be taken after a thorough analysis of the verdict and inter-ministerial consultations.
Who bears the cost?
The new tax demand has sparked a bureaucratic dispute within the Polish government. The finance ministry points to the health ministry as the responsible payer, while the health ministry insists the liability falls on the state budget. If the health ministry’s budget is ultimately charged, it could force cuts in other areas, including diagnostic funding by the National Health Fund.
Poland’s attempts to reach a settlement with Pfizer and BioNTech in 2023 failed. The original contract was negotiated and signed by the European Commission under Belgian law, which is why the case is being heard in Brussels.
Źródło: WNP.PL, Fot. PTWP
