JPK CIT obligation in a nutshell

For the largest taxpayers the first reporting year will be 2025 with deadline for filing 31st March 2026. For majority of other taxpayers, the first reporting year will be 2026 with deadline for filing 31st March 2027. New regulations will require adaptation of IT software or adoption of IT tools, review of accounting and tax processes, tax mapping of accounts, collection of additional data, personnel training and consistency checks with other reporting obligations. Therefore, it is recommended for all taxpayers to commence preparation for JPK CIT implementation.

Context of new tax regulations

Implementation of the JPK CIT is the next step in digitalization of tax reporting in Poland. Starting from 1^st July 2018, all taxpayers running tax and accounting books and producing accounting evidence in electronic form are obliged to submit on request of tax authorities the JPK_KR standard audit file for accounting books in required logical structures xml format.

In 2024 the Ministry of Finance announced works on implementation of the new JPK CIT reporting format for CIT purposes that will require supplementing the accounting books by additional information in defined new logical structures.

One of the goals of JPK CIT implementation is to provide tax authorities with regular insights into taxpayers’ CIT settlements. This will allow tax authorities, among other things, to more effectively detect irregularities in CIT settlements and select taxpayers for tax inspections.

Taxpayers subject to new regulations and timetable

The obligation to produce and file JPK CIT will be implemented gradually, depending on the taxpayers category:

• Obligation to submit JPK CIT for the tax year starting after 31^st December 2024 – obliged to produce and file JPK CIT will be large taxpayers whose revenue obtained in the previous tax year or fiscal year exceeded the equivalent of EUR 50 million, as well as tax capital groups.
• Obligation to submit JPK CIT for the tax year starting after 31^st December 2025 – obliged to produce and file JPK CIT will be all taxpayers obliged to file JPK VAT (vast majority of taxpayers).
• Obligation to submit JPK CIT for the tax year starting after 31^st December 2026 – obliged to produce and file JPK CIT will be all categories of taxpayers.

For the largest taxpayers, the deadline for first JPK CIT reporting for 2025 will be as a rule 31^st  March 2026.

For majority of other taxpayers, the deadline for first JPK CIT reporting will be as a rule 31^st March 2027 and for the rest of taxpayers, the deadline for first JPK CIT reporting will be as a rule 31^st March 2028.

Scope of new requirements

The new JPK CIT requirements consist of obligation to file the following produced logical structures in xml format:

• JPK_KR_PD – an extended version of the current JPK_KR logical structure, with new additional data,
• JPK_ST_KR – a new logical structure covering information on fixed and intangible assets.

The scope of required information in JPK_KR_PD and JPK_ST_KR logical structures will vary depending on category of taxpayer. Further, in the first year certain information will be facultative.

JPK CIT reporting will be additional to standard annual CIT-8 return.

Specific exemptions and simplifications

The new regulations on JPK CIT reporting provide for certain exceptions, among others:

• Taxpayers objectively exempted (except family foundations), taxpayers allowed to report CIT in hard copy, taxpayers reporting only certain categories of CIT-exempted profits, taxpayers keeping simplified revenues and costs records – will be exempted from the obligation to file JPK CIT.
• Taxpayers preparing financial statements pursuant to Article 45 (1a) and (1b) of the Act of Accounting of Law September 29, 1994, in accordance with the International Accounting Standards, International Financial Reporting Standards Financial Reporting Standards and related interpretations promulgated in the European Commission regulations referred to in Article 2 (3) of the Accounting Act – will be allowed to file JPK CIT in simplified format (with no tax mapping required) for the tax year that begins after December 31^st 2024 and ends before 1^st January 2026.
• For all taxpayers certain categories of information required in JPK CIT (i.a. tax identification number of the contractor, KSeF e-invoice number) will be facultative for the tax year that begins after December 31^st 2024 and ends before 1^st January 2026.
• Entities initially obliged to report JPK CIT in the first year of the provisions being in force are to be temporarily released from the obligation to submit data regarding the records of fixed assets and intangible assets (JPK_ST_KR) – based on the draft regulation published by the Ministry of Finance on 15^th  November, 2024,  Nevertheless, entities required to submit JPK_KR_PD starting from 2025 will be still obliged to introduce required changes to the registers of fixed assets and intangible assets, since these data will have to be reported in the subsequent years (after 2025).

How to prepare?

Despite the fact that the JPK CIT reporting for the first group of taxpayers will be in 2026, actions should be taken earlier. This would allow recording data in required format in course of the tax year.

Proper preparation will require engagement of various departments within the entity and multidisciplinary approach.  The following steps and challenges should be taken into account:

• Producing JPK CIT is the final stage of the process. In previous stages, analysis of requirements as well as further implementation of the new formats for data reporting in IT software will be necessary.
• In order to use properly the new formats for data reporting in IT software, review and amendments in accounting and tax processes may be required.
• Amendments in accounting and tax processes will require staff trainings.
• Implementation of JPK CIT will require mapping of the chart of accounts to the accounting and tax tags list given by the Ministry of Finance.
• One of the goals of JPK CIT implementation is to provide tax authorities with regular insights into taxpayers’ CIT settlements. Thus, a CIT review aimed at identification of risk areas may be a recommended option in course of JPK CIT implementation.
• New regulations will require adaptation of existing IT software. In cases where your service provider would not prepare necessary functionalities, adoption of external tools for producing JPK CIT will be necessary.
• Given other reporting requirements, it should be considered to perform a “dry run” for JPK CIT as well as to perform consistency check with other electronic reporting.

How could we help?

Forvis Mazars offers a multidisciplinary approach to JPK CIT implementation, bringing together tax, accounting, and technology expertise. The specific approach should be tailored to each organization’s needs. Our support may include:

1.      Accounting Area

The main aim of this phase is to map the entity's chart of accounts to the accounting tags of the JPK CIT structure.

STEP 1: Analysis of the structure of accounting data in terms of JPK CIT requirements.

STEP 2: Recommendation and support in implementing necessary changes in the chart of accounts/organization of accounting processes.

STEP 3: Mapping the chart of accounts to accounting tags to the JPK CIT schema.

2.      Tax area

The purpose of the following activities is to determine tax tags for individual tax transition items, link them to the chart of accounts and map them to the JPK CIT structure.

We also recommend to take the opportunity to verify the correctness of income tax calculation and assess potential tax risk within the entity.

STEP 1: Analysis of processes related to the preparation of income tax calculations.

STEP 2: Verification of the correctness of income tax calculations.

STEP 3: Assigning tax tags to individual tax transition items and chart of accounts.

STEP 4: Recommending and implementing necessary changes to the chart of accounts for correct mapping to tax tags.

3.      Technology

Analysis of technological readiness in the field of JPK CIT. Support in implementing JPK CIT functionality in the current ERP system or implementation of an external solution based on data downloaded from the ERP system. In some cases this phase may be carried out with external IT tools providers.

4.      Trainings and support

 The last phase of the implementation process may include:

• Assistance in “dry run” of IT software / IT tool for JPK CIT reporting.
• Support in consistency check with other required reporting, e.g. JPK_KR.
• Preparation of JPK CIT producing, testing and filing procedure.
• Trainings of the accounting teams.