JPK CIT – new reporting obligations for businesses starting next year. How to prepare?

Key highlights of the new regulation

1. Electronic bookkeeping:

Businesses will be required to maintain their accounting books exclusively in electronic form. These records must be submitted to the tax authorities in a specific logical structure known as JPK CIT, which consists of two files:

• JPK_KR_PD – containing information on accounting records and corporate income tax,
• JPK_ST – covering the fixed assets and intangible assets register.

2. New reporting data:

Businesses will need to report more detailed information, including data on contractors, invoices (including those from the National e-Invoicing System), differences between accounting and tax results, and detailed records of fixed assets.

3. Technical requirements:

Companies will need to upgrade their financial systems to ensure they can generate and submit JPK CIT files that meet the new specifications.

Who will be affected by JPK CIT?

The rollout of JPK CIT will be phased in, with different timelines for various taxpayer groups:

• By December 31, 2024: CIT taxpayers with annual revenue exceeding EUR 50 million and tax capital groups must comply. They will submit the first JPK_KR_PD files in 2026 for fiscal years beginning after December 31, 2024.
• By December 31, 2025: the obligation will cover all VAT taxpayers who are required to submit JPK_VAT.
• By December 31, 2026: all remaining CIT taxpayers will be required to submit JPK CIT.

Structure of JPK CIT

JPK CIT is composed of multiple elements, with the primary ones captured in the JPK_KR_PD and JPK_ST_KR files. These structures have been officially approved by the Ministry of Finance, aiming to improve the transparency and monitoring of tax compliance.

JPK_KR_PD – Corporate Income Tax

JPK_KR_PD encompasses a company’s accounting data, including the full journal of entries, turnover and balance summaries, as well as key information about taxable income and expenses. Key components include:

• Identification data – basic information about the taxpayer and the reporting period.
• Accounting account markers – these tags link the taxpayer’s chart of accounts to the standard chart, facilitating tax administration, which simplifies tax administration. Mandatory for International Financial Reporting Standards (IFRS) taxpayers from 2026, and for those applying the Polish Accounting Act (UOR) from 2025.
• Accounting entries (Journal) – covering all business transactions during the reporting period.
• Turnovers and balances (ZOiS) – summary of all turnovers and balances in accounting records.
• Tax information – additional data used to settle CIT via tax markers.
• Contractor data – a detailed list of the taxpayer’s contractors.

If the JPK_KR_PD file is too large due to high transaction volumes, it can be split into smaller sections for easier handling.

JPK_ST_KR – Fixed Assets

JPK_ST_KR relates to the fixed assets register and contains detailed information about a company’s long-term assets. It includes both tax and balance sheet data. The key components are:

• Identification data – information about the taxpayer and the reporting period.
• Fixed assets register – a complete list of all fixed assets owned by the taxpayer.
• Classification of fixed assets (KŚT) – classification of fixed assets according to the National Fixed Assets Classification (KŚT).
• Intangible assets register (WNiP) – a list of intangible assets such as licenses, patents, and copyrights.
• Depreciation schedule – details on depreciation deductions, including periods and methods of depreciation.
• Fixed assets transactions – data on the acquisition, sale, disposal, or movement of fixed assets during the reporting period.

Exemptions from JPK CIT reporting

Not all taxpayers are required to submit JPK CIT files. Exemptions include:

• Taxpayers exempt from corporate income tax, except for family foundations,
• Taxpayers eligible to file tax returns in paper form,
• Businesses keeping simplified records of revenues and expenses.

How to prepare for the JPK CIT transition?

Implementing JPK CIT represents a significant shift for companies, requiring careful preparation across IT systems and internal processes. Here are the critical steps businesses should take to ensure a smooth transition:

1. Evaluate data and processes

Conduct a thorough analysis of the data that will need to be reported and assess how the new requirements will impact your accounting and tax processes. Identifying gaps in your current systems is crucial to avoid difficulties in generating JPK CIT files.

2. Upgrade financial systems

Financial and accounting systems must be updated to meet the new requirements, ensuring that they can generate the correct JPK CIT file structures.

3. Train your team

With JPK CIT comes the need for staff training, particularly for employees responsible for accounting and taxes. Investing in training to understand the new obligations can prevent reporting errors.

4. Partner with experts

Companies may benefit from the expertise of tax advisors or IT specialists to properly implement the changes. Consider working with implementation partners who can help configure ERP systems and integrate JPK CIT solutions.

The challenges and benefits of JPK CIT implementation

The introduction of JPK CIT is another step towards digitalizing tax processes in Poland. While it requires companies to adjust their systems and processes, in the long run, it promises benefits such as simplifying tax filings, speeding up the submission process, and reducing errors. Success in this transition depends on thorough preparation, both technically and organizationally.

If you need assistance with implementing JPK CIT in your company, reach out to our team. We can help you adapt your processes and Microsoft Dynamics 365 systems to meet these new requirements.