Belgian authorities have initiated enforcement proceedings against Poland, demanding nearly 200 million złoty in registration tax and fees tied to the disputed COVID-19 vaccine contract. The move adds a new layer to the ongoing legal battle after a Brussels court ordered Poland to pay 5.65 billion złoty to Pfizer and BioNTech for undelivered vaccine doses.
The original judgment, handed down on 1 April 2026 by the French-language Court of First Instance in Brussels, ruled that Poland must compensate the pharmaceutical companies for 60 million COVID-19 vaccine doses it refused to accept. Poland argued force majeure due to the Russian invasion of Ukraine, but the court found no grounds to alter the contract terms.
Now, the Belgian tax authority has issued a notice demanding payment of 39.57 million euro – roughly 170 million złoty – as a 3% registration tax on the awarded sum. Additional enforcement and administrative fees of over 11,000 euro bring the total to nearly 200 million złoty.
Poland questions legality of tax demand
The Polish health ministry confirmed it received the enforcement notice but has not paid. Instead, Warsaw sent a diplomatic note to Belgian authorities seeking clarification on whether the compulsory registration tax applies to disputes involving European Union member states. As of now, no response has been received.
– We are taking all available legal steps to protect Poland’s interests and will analyze the judgment thoroughly before deciding on further actions – said a spokesperson for the Polish health ministry after the initial court ruling.
The health ministry is now locked in a dispute with the finance ministry over who should cover the costs. The finance ministry points to the health budget, while the health ministry insists it should come from the state budget.
Political fallout and budget pressures
If the burden falls on the health ministry, it would worsen already strained finances. Recent cuts to diagnostic funding by the National Health Fund have sparked opposition attacks on the government. While 170 million złoty is a relatively modest sum in the overall system, it represents a real expenditure that could fuel further political tensions.
The entire vaccine saga stems from a contract negotiated by the European Commission under Belgian law, which gave the Brussels court jurisdiction. Poland attempted to renegotiate in 2023 but failed, leading to the lawsuit. The health ministry maintains it acted in the national interest during the pandemic.
The government now faces a tough choice: pay the additional tax under protest or risk further enforcement actions by Belgian authorities. The diplomatic route may buy time, but the legal and financial pressure continues to mount.
Źródło: WNP.PL, Fot. PTWP
