JPK CIT in Poland – a new reporting obligation for Polish CIT taxpayers from 2025 | News Flash

The digitization phase in tax settlements will not bypass Polish CIT taxpayers. The scope of the new SAF-T (JPK_CIT) will consist of two structures: JPK_KR_PD for accounting books and JPK_KR_ST for fixed assets and intangible assets. Starting from tax years beginning on January 1, 2025, certain types of taxpayers will be obligated to submit annual JPK CIT files to tax authorities in XML format without prior request from them.

JPK – current regulations

Currently, certain JPK structures in Poland are to be sent at the request of the tax authorities as part of tax audits or verification activities. One of the JPK structures that needs to be sent upon request is JPK_KR (related to accounting books). JPK_CIT is an extension of the existing JPK_KR structure.

JPK CIT in Poland – a new obligation

From January 1, 2025, there will be an obligation to keep accounting books exclusively in electronic form and to send the structured information contained therein to the Polish tax authorities every year – specifically through the JPK_CIT structure.

JPK_CIT reporting will introduce two new structures:

• JPK_KR_PD – single control file for ledgers and income tax settlements
• JPK_ST_KR – single control file for fixed assets and intangible assets.

Compared to the existing JPK_KR structure, the new JPK_KR_PD structure will impose an obligation to collect and report new data such as:

1. The taxpayer’s counterparty tax identification number
2. The invoice identification number in the National e-Invoice System, if it has been assigned by the date of submission of the ledger
3. Book account identification tags shown according to the dictionary of book account identification tags
4. Data confirming the acquisition, creation or deletion of a given fixed asset or a given intangible asset from the records of fixed assets and intangible assets
5. The amount of the difference between the financial result determined on the basis of accounting regulations and the tax base determined on the basis of corporate income tax regulations, broken down into the categories specified in the regulation.

JPK CIT – who will be affected by the obligation?

JPK CIT in Poland will be introduced in stages according to a schedule set by the Polish Ministry of Finance. In the first instance (i.e., for a tax year or fiscal year beginning after December 31, 2024), it will cover:

• CIT taxpayers whose value of income earned in the previous tax year (or fiscal year in the case of non-corporate companies) exceeded EUR 50M
• tax capital groups.

These groups of taxpayers from the beginning of 2025 will have to include only one element in the logical structure of the accounts: tags identifying the accounts of the books. Only from January 1, 2026 they will have to indicate the counterparty identification number, the invoice identification number in the National e-Invoice System, the amount, type and type of difference between the balance sheet and tax result.

New obligations for CIT taxpayers will be implemented according to the following schedule for tax years starting after:

• December 31, 2024 in the case of tax capital groups and CIT taxpayers whose revenue value in the previous tax year exceeded EUR 50 million
• December 31, 2025 in the case of other CIT taxpayers required to submit JPK_VAT records
• December 31, 2026 in the case of other CIT taxpayers.

What is the deadline for filing JPK CIT in Poland?

According to the wording of the CIT Act, which will take effect on January 1, 2025, every year CIT taxpayers will have to file a JPK_CIT, without a prior request from the tax authorities. The deadline for JPK_CIT is the same as the deadline for filing the CIT-8 tax return (for the taxpayer, the tax year coincides with the calendar year, the deadline for filing the JPK_CIT will be the end of March of the following year).

How to prepare for the implementation of JPK CIT in Poland?

Preparing for JPK_CIT implementation requires taking a number of comprehensive steps. In order to ensure compliance with the new regulations, it is worth taking key steps, such as:

• Analyzing the completeness of data in the financial and accounting system against the requirements of the JPK CIT structure. If gaps or deficiencies are identified, appropriate corrective actions should be taken, which may require adjustments to existing financial and accounting systems
• Analyze the chart of accounts and the current tax calculation process against the requirements of the new schema. Due to new reporting requirements in many organizations, the company’s chart of accounts may need to be expanded or updated
• Mapping data from the ERP system to the appropriate fields of the JPK_CIT structure and adding mandatory tags identifying ledger accounts according to defined dictionaries
• Adaptation of existing systems to the new JPK_CIT requirements. This may include the need to implement new technological solutions or expand and customize the modules already in place. In the case of older versions of ERP systems, they may need to be upgraded to newer versions to meet the requirements.

JPK CIT – challenges

The implementation of regulations regarding JPK CIT in Poland will require adjustments to financial and accounting systems to meet the new reporting standards. Failure to adequately adapt may result in difficulties in fulfilling the obligations imposed by the legislator, which could lead to severe penalties and sanctions.

A key element in the preparation process will be assessing whether the currently used financial and accounting system meets the new requirements. If there is a risk that the system will not ensure full compliance, for example, due to the lack of a comprehensive localization package, additional modifications may be necessary. In the case of older system versions or foreign solutions without dedicated localization, adapting to the new requirements may entail high costs. An alternative in such a situation could be upgrading to a newer system version or replacing the system entirely.

In addition to technological adjustments, due to the complexity of the new structure and the need to collect additional data, modifications to the chart of accounts and processes related to CIT calculation and the recording of fixed assets may also be required.

Support from Accace

Our team of experts has deep knowledge and experience in tax, automation, and the implementation and handling of JPK files, which allows us to offer tailored support to meet an organization’s individual needs. Our approach is comprehensive – from the analysis of the current state to implementation and configuration support, to adjusting the organization’s processes to meet the numerous requirements resulting from regulatory changes. Our support includes, among others:

• Analyzing and reviewing the readiness of data and processes in the organization to meet the requirements of the new responsibilities and structures
• Mapping of data from the ERP system to the relevant fields of the JPK_CIT structure
• Support of internal and external IT teams during implementation and configuration of systems,
• Support during customization, change or upgrade of the financial and accounting system
• Verification of the correctness of generated JPK files and support during testing of implemented system solutions.

By leveraging our expertise, you can ensure your company a smooth transition to the new regulations and avoid the risk of non-compliance. We invite you to contact us to learn how we can assist your organization in the effective implementation of JPK_CIT.

Marcin Pezowicz

BPO Process Consultant | Accace Poland

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