New JPK_CIT reporting regulations from 2025 – changes in tax reporting

On 16th of August 2024, the Minister of Finance signed a key regulation regarding the Standard Audit File for Corporate Income Tax (JPK_CIT), which entails significant changes in the area of tax reporting. With the new regulations coming into effect on 1st of January 2025, the provisions will firstly apply to the largest taxpayers and capital groups, which will be required to submit already the reports for the year 2025.

Key changes related to JPK_CIT

The regulation introduces the obligation to report two key structures:

• JPK_KR_PD – includes, among others, a summary of turnovers and balances, entries in accounts, and so-called tax markers that indicate how specific transactions have been recorded for tax purposes.
• JPK_ST_KR – concerns the recording of fixed assets and intangible assets (fixed assets and intangible assets).

Varied reporting scope:

• Mandatory elements – required from the beginning of the first reporting period.
• Optional elements – optional or implemented gradually.

An important change compared to previous drafts is the requirement to report the records of fixed assets and intangible assets in the first year of the regulations’ effectiveness.

Implementation timelines

The Ministry of Finance has planned a gradual introduction of JPK CIT, depending on the group of taxpayers:

• For the year starting after 31 December 2024: taxpayers with revenues exceeding €50 million and tax capital groups (PGK).
• For the year starting after 31 December 2025: all CIT taxpayers required to submit JPK_V7.
• For the year starting after 31 December 2026: all other CIT taxpayers.

What JPK CIT means for tax risk management?

The new regulations introduce significant changes in the area of tax risk for businesses:

• Increased risk of tax audits – JPK CIT enables the tax administration to more accurately target entities for audits.
• Risk of data inconsistencies – the requirement to report consistent data increases the risk of discrepancies being detected by tax authorities.
• Risk related to data accuracy – the level of detail required in the information raises the risk of reporting errors, which may lead to penalties.

How to prepare for JPK CIT reporting?

Preparing for the reporting of the Standard Audit File for Corporate Income Tax (JPK CIT) is a process that requires diligence and consistency. The biggest challenge will be the appropriate application of tax markers. Sample questions that may arise include how to mark hypothetical interest costs, debt financing costs, or income from capital in kind benefits. It is strongly recommended to start analyses regarding effective solutions in this area as soon as possible.

To effectively prepare for reporting, businesses should focus on several key steps. Firstly, it is necessary to collect all essential financial and tax data, including revenues, costs, and any other transactions that affect the differences between financial and tax accounting. The second step is to carefully check the accuracy of this data to ensure that all transactions are correctly recorded and that documents are complete and compliant with applicable regulations. Subsequently, businesses should invest in appropriate software to generate files in the required XML format, and conduct tests and verifications of the file before its final submission. Adhering to these steps will facilitate the smooth and trouble-free preparation of JPK CIT, minimising the risk of errors and inconsistencies in reporting.

Summary

JPK CIT represents a significant change in tax reporting for companies in Poland. Although the implementation is spread over time, all CIT taxpayers should start preparing for their new obligations now. It is crucial to understand the scope of the required data and to adapt systems and processes for effective JPK CIT reporting.

It is strongly recommended to begin preparations as soon as possible, which will ease the adjustment process to the new requirements and minimise the risk of potential problems in the future.

In the process of adapting to the new tax reporting requirements, it is beneficial to seek professional support. Contact us to discuss how we can jointly prepare your business for the new obligations related to JPK_CIT.

If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.

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