Accounting books of foreign branches vs. JPK_CIT: what Polish tax authorities expect

Until recently, the accounting books of foreign branches were mainly associated with local reporting duties in the country where the branch operates and with feeding data into the Polish head office’s financial statements. With the introduction of structured reporting of accounting records under SAF-T for corporate income tax (JPK_CIT), the dispute has shifted to a new level: does a Polish company need to report to Polish tax authorities also the accounting entries of branches (permanent establishments) located outside Poland? For groups running accounting in Poland at head-office level, this question directly affects data governance, reporting design, and cross-border finance operations.

In an individual tax ruling dated 3 October 2025, the Director of the National Tax Information (KIS) challenged the taxpayer’s position and adopted an approach that, in practice, can mean the need to include data from self-balancing foreign branches in JPK_KR_PD reporting. For companies with foreign operating structures, this may translate into additional costs, redesign of finance and accounting processes, and data-quality risks.

The typical model of foreign branches in Polish companies

In many groups expanding abroad, branches operate as self-balancing units. This usually means that:

• branches keep books in line with the accounting law of the country where they operate,
• they prepare their own financial statements,
• and their financial data is later consolidated at the level of the Polish head office for statutory reporting.

This model is business-rational: it helps meet local requirements, supports management transparency, and reduces duplicated record-keeping. In practice, however, it does not answer whether branch accounting entries must be adapted to the Polish JPK_CIT structures.

What follows from the 3 October 2025 ruling

The core question is who is obliged to keep accounting books and submit them in a structured format.

In the ruling, the company argued that foreign branches keep books under local rules, and that the Polish Accounting Act does not require maintaining their books under Polish standards—neither in parallel nor as auxiliary records. As a result, in the company’s view, those branches should not be reported in the JPK_KR_PD structure.

The Director of KIS took a different view. He indicated that the entity obliged to keep accounting books — also with respect to self-balancing foreign branches — is the Polish company. Therefore, the company is responsible for obligations under Article 9(1c) of the Corporate Income Tax Act (CIT Act), which (in this approach) also covers data from those branches.

From a business perspective, this is not only about “technical” reporting. It forces an organisational decision: how to make foreign branch data compatible with Polish JPK structures without breaking local compliance and without undermining reporting quality.

JPK_CIT: a gap between the regulatory goal and the reporting scope

In principle, structured reporting of accounting books is meant to help tax authorities verify CIT settlements by aligning accounting data with the annual tax return.

The problem with foreign branches is that:

• branch accounting is typically embedded in a different accounting regime (local standards, local charts of accounts, different dictionaries),
• and the tax consequences of the branch’s activity are often settled in the branch’s country (depending on the operating model, double tax treaties, and local rules).

This creates real tension between Poland-specific technical structures and the practical reality of running business through a branch or permanent establishment abroad.

What files does JPK_CIT include and how do they relate to accounting books?

In the CIT area, two key JPK structures apply:

• JPK_KR_PD – structured accounting books for income tax purposes,
• JPK_ST_KR – fixed assets register.

The implementation schedule depends on the taxpayer group (including revenue thresholds and the status of a tax capital group), and then expands to a broader set of entities keeping full accounting books. Importantly, deadlines and reporting scope have been adjusted in practice via executive regulations (for example, by extending filing deadlines for selected financial years).

For Polish companies with foreign branches, this means JPK_CIT should be treated not as a one-off file to submit, but as a broader project covering:

• the data model (what must exist in the books),
• mapping of accounts and dictionaries,
• data flows from branches to the head office,
• data quality control (consistency, completeness, compliance).

Why foreign branches are particularly challenging for JPK reporting in Poland

1) Different accounting standards and charts of accounts

Branches record transactions under local requirements. Even if a group uses common management reporting principles, local records may be kept at a different level of detail and in a different account structure.

2) Multi-currency data and conversion rules

Consolidation into the Polish entity’s financial statements follows specific conversion and presentation rules. However, JPK_KR_PD focuses on the accounting books, i.e., transaction-level entries — not only the final reporting outcome.

3) Risk of duplicated record-keeping

If a company concludes it must provide branch data in a Poland-expected format, it may need parallel processes: transforming branch data into Polish structures or maintaining additional auxiliary records.

4) Operational impact

In practice, JPK_CIT increases expectations for transaction-level data standards: document identifiers, attributes, account tags, and consistency across the organisation.

Practical consequences: what companies may need to do

For companies with foreign branches, the key step is moving from debating the interpretation to designing solutions that reduce compliance risk and implementation cost. In practice, it helps to structure work across three areas.

Area 1: classify the foreign operating model

• Does the activity take the form of a branch/permanent establishment with its own records and local obligations?
• What data is currently transferred to Poland (statutory reporting packages, management reporting, consolidation packs)?
• Can the head office move from aggregated reporting down to the level required for accounting books?

Area 2: data architecture for JPK_KR_PD

• What does the head office chart of accounts look like—and can it be aligned with branch charts?
• Do branch accounting systems allow exports that can be transformed into the JPK structure?
• How will you ensure identification of documents, counterparties, and required attributes in branch data?

Area 3: data quality control and accountability

• Who is accountable for branch data completeness in JPK: the branch, head office, or a joint team?
• How will the audit trail be documented—from local source data to the data reported in Poland?
• How do you reduce inconsistency risk between local reporting and the transformed JPK dataset?

Two JPK_CIT files and foreign branches: how to approach this in practice

Companies typically start with JPK_KR_PD because it covers accounting books and tends to be the most information-dense. It is also worth noting that a temporary exemption was introduced for submitting JPK_ST_KR for specific periods (in particular, for a tax year starting after 31 December 2024 and before 1 January 2026).

Regardless, fixed assets and intangible assets registers should be prepared process-wise and system-wise, because the reporting obligation will apply to later periods.

When designing the process for foreign branches, it is important to decide early whether you will:

• report branch data directly (when systems and data allow mapping),
• build a data transformation layer (ETL) into the JPK structure,
• or maintain auxiliary records in Poland solely for reporting purposes.

Each approach has different costs, different error-risk profiles, and a different impact on data governance and accountability.

What if the company disagrees with the tax authorities’ approach?

An individual ruling provides protection only within the factual scenario described in the application. If your company has a specific branch operating model (e.g., a different level of self-balancing, different record-keeping, different data-flow organisation), it may be worth formalising your position and assessing whether requesting your own ruling is justified from a business perspective.

At the same time, regardless of interpretative disputes, reporting obligations are practical — and failure to meet them can create risk in dealings with tax authorities.

If your company has foreign branches and is preparing for JPK_CIT reporting, a consistent approach to data and accounting Poland requirements is essential. getsix® can support you through accounting services in Poland and tax advisory in Poland.

FAQ – questions most often asked by companies with foreign branches

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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