JPK_PD – commonly referred to as JPK_CIT – is a new file structure containing data from accounting books that must be submitted to the Polish tax office. Currently, JPK_CIT_KR is already in use, but it is submitted only upon request by Polish tax authorities.

Under the new regulations, there is an obligation to submit certain files annually.

For CIT taxpayers, the new JPK_PD structure will include the following files:

• JPK_KR_PD (Standard Audit File – Accounting Records for Corporate Income Tax) – a structure covering entries from accounting books, extended with additional information.
• JPK_ST_KR (Standard Audit File – Fixed Assets) – a new structure covering records of fixed assets and intangible assets.

Regulations

The obligation to report JPK_CIT is introduced by the Regulation of the Polish Minister of Finance of August 16, 2024, concerning additional data that must be included in accounting books submitted under the Polish Corporate Income Tax Act. The legal basis is Article 9(1c) and (5) of the Polish CIT Act, as effective from January 1, 2025.

Taxpayers exempt from JPK_CIT obligations include:

• Those exempt from corporate income tax by law (Article 6(1)), with the exception of family foundations.
• Those earning only tax-exempt income under Article 17(1) of the CIT Act and who are not required to prepare declarations or reports referred to in Article 29a of the CIT Act (e.g., associations).
• Those maintaining simplified records of income and expenses (e.g., rural community groups).

Article 27a [Exemption from the obligation to submit returns and information electronically]

The return referred to in Article 27(1) may be submitted in paper form by taxpayers who earn only
tax-exempt income under Article 17(1) and who are not required to prepare declarations or information referred to in Articles 35(10), 38(1a) and (1b), 39(1–4), 42(1a–4), 42a(1), and 42e(5) and (6) of the Act of July 26, 1991, on Personal Income Tax.

Key aspects that will shape Polish accountants’ daily work after implementing JPK_CIT:

• Additional responsibilities and organizational challenges.
• Ensuring the chart of accounts is compliant with the new standards.
• Ongoing quality control of accounting data.
• Employee training on new reporting requirements.
• Close collaboration with financial/accounting software providers – only up-to-date systems ensure correct generation of JPK_CIT files.
• Continuous monitoring of communications from the Polish Ministry of Finance.
• Precise posting and mapping of every transaction in real time.
• Maintaining books in a consistent and transparent manner throughout the year.
• Potential improvements in internal control and financial management thanks to structured data.
• Possible facilitation of communication with banks and auditors through a standardized file format.

Due to numerous doubts regarding the obligations related to reporting JPK_KR_PD and JPK_ST_KR, the Polish Ministry of Finance has published a set of answers to frequently asked questions (Q&A). The purpose of the publication is to clarify emerging uncertainties in this area.

Although this document does not constitute a legally binding source of law, it indicates the Ministry of Finance’s expectations regarding the future method of reporting JPK_CIT files.

Below, we present what we consider the most important answers from the Polish Ministry of Finance regarding obligations related to JPK_CIT.

Is it possible to split the JPK_ST_KR file in case of a large amount of data? A company has 2 million fixed assets in its current fixed assets register. In such a case, is it possible to generate two separate JPK_ST_KR files?

There is no provision for splitting the JPK_ST_KR file.

Will taxpayers maintaining full accounting books no longer be required to provide the JPK_KR (1) file upon request, and instead be required to submit the JPK_KR_PD (1) file only once a year?

The introduction of JPK_KR_PD does not eliminate JPK_KR on request. JPK_KR will continue to be used, among other things, for periods prior to the entry into force of the mandatory JPK_KR_PD reporting.

Does the €50 million revenue threshold, used to determine when the new structures must be applied, refer to tax revenue or accounting revenue?

The above-mentioned €50 million revenue threshold refers exclusively to revenue determined under tax law.

Assuming the tax year is a calendar year, to determine whether the new JPK_KR structures must be applied from 01.01.2025, should revenue from 2023 or 2024 be considered?

Starting from January 1, 2025, the base year for assessing the €50 million revenue threshold will be the tax year preceding the year in which the JPK_KR_PD obligation applies for the first time, i.e., 2024.

Will legal entities be required to submit JPK_KR_PD for the year starting after 31.12.2025 or after 31.12.2026?

For the corporate income tax (JPK_CIT) obligation for the tax/financial year starting after December 31, 2025, it will apply to CIT taxpayers and non-legal entity companies […] other than those specified in point 1) who are required to submit JPK_VAT.

Should fixed assets that were fully depreciated both accounting-wise and for tax purposes before January 1, 2025, be reported in the JPK file?

When reporting the JPK_ST_KR logical structure, all fixed assets currently held by the entity – that is, recorded in the fixed assets register – must be included. Fixed assets disposed of before January 1, 2025, should not be reported.

In the case of disposing of an undepreciated fixed or intangible asset, should the net value recognized as a tax deductible cost be reported in JPK_ST_KR? If so, in which field?

In the case of disposing of a fully undepreciated fixed or intangible asset, the undepreciated value should not be reported in JPK_ST_KR.

A client plans to change their financial/accounting system halfway through next year and mentioned they intend to prepare two JPK_KR_PD files (one for the first half of the year from the old system, and another for the second half from the new system). Would such an approach be acceptable?

JPK_KR_PD files can be generated for any periods; however, the continuity of the entries will be verified.

How and to which tax office will the taxpayer be required to submit the new JPK_KR and JPK_ST_KR files?

According to Article 9(1c) of the CIT Act, “taxpayers maintaining accounting books are required to keep these books using computer programs and submit them to the competent head of the tax office after the end of the tax year, by the deadline for filing the return referred to in Article 27(1) or the declaration referred to in Article 28r (1).

JPK files should be generated using accounting software and sent directly from the program if it has a JPK file submission function. Submission can also be carried out using the JPK WEB client application.

The introduction of the Polish JPK_CIT reporting obligation is not only a technological and process challenge but primarily a substantive one. Maintaining accounting books and settling Polish corporate income tax (CIT) has never been so easily accessible. At the same time, reviewing corporate income tax settlements has never been so urgent and necessary.

As part of preparing for JPK_CIT reporting in Poland, we particularly recommend and emphasize examining CIT settlements in light of the data now regularly provided to the tax office.

How will the Polish tax office approach JPK_CIT data? Which areas are the most likely to be reviewed?

• Full access to accounting data: individual postings, counterparty records, trial balances, and account summaries.
• Transparency of the transition from accounting profit to taxable profit.
• Ability to compare companies within the same industry: analysis of margins, revenue and cost structure, external financing, and group services.
• Verification of accounting and tax depreciation rules.
• Assessment of CIT underreporting risk without initiating a formal tax audit.
• Increased importance of ongoing analysis of tax-deductible costs.
• Necessity to implement internal tax review processes for continuous monitoring of data accuracy.