JPK_KR_PD and foreign branches – new approach of the Polish tax authority to reporting accounting records

JPK_KR_PD and foreign branches has been one of the areas raising significant doubts since the introduction of new JPK_CIT obligations in Poland. JPK_KR_PD is the Polish Standard Audit File structure for reporting accounting books for corporate income tax purposes. The issue is particularly relevant for Polish companies that have self-accounting foreign branches, meaning branches that keep their own accounting books and prepare separate financial statements in accordance with local accounting rules.

In an individual tax ruling issued on 2 April 2026, the Director of the National Revenue Information (KIS) confirmed a favourable position for taxpayers. According to the ruling, the obligation to keep accounting books and submit them to the competent head of the tax office after the end of the tax year, resulting from Article 9(1c) and 9(1e) of the Polish Corporate Income Tax Act, should not cover accounting books kept independently by self-accounting foreign branches of a Polish company.

This is an important shift in the approach to JPK_KR_PD reporting. Earlier positions of the tax authorities could have led to the conclusion that a Polish company should also include data from the accounting books of its foreign branches in Polish JPK reporting. In practice, this could have meant adapting foreign accounting records to the Polish logical structure of JPK, even though those branches keep their books under the regulations of the country in which they operate.

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Why is this ruling important for Polish companies with foreign branches?

The new JPK_CIT obligations mean that taxpayers keeping accounting books are required to maintain them using accounting software and submit them after the end of the tax year in the relevant logical structure. For accounting books, this structure is JPK_KR_PD, i.e. the Standard Audit File for corporate income tax accounting books in Poland.

For companies operating only in Poland, the scope of the obligation is generally easier to determine. More doubts arise when a Polish company has a foreign branch that:

• keeps its own accounting books,
• prepares separate financial statements,
• operates under local accounting regulations,
• is later included in the combined financial statements of the parent entity.

In such a model, the branch’s data is relevant for the reporting of the entire entity. However, this does not automatically mean that the branch’s accounting books should be submitted to the Polish tax authority as part of JPK_KR_PD.

The Director of the National Revenue Information indicated that, in this type of situation, the Polish Accounting Act primarily concerns the rules for preparing combined financial statements and including the relevant data from the balance sheets and profit and loss accounts of foreign branches. It does not mean, however, that the Polish Accounting Act regulates the way such foreign branches keep accounting books abroad.

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What exactly did the Director of the National Revenue Information confirm?

The individual tax ruling of 2 April 2026 concerned the question of whether a Polish company is required to submit to the competent head of the tax office the accounting books kept by a self-accounting foreign branch.

The authority considered the taxpayer’s position to be correct. In practice, this means that the JPK_KR_PD reporting obligation should not cover accounting books kept independently by a foreign branch, provided that those books are maintained in accordance with the adopted accounting policy and the local regulations applicable in the country where the branch operates.

The key conclusion is as follows: a Polish company does not have to submit the full accounting books of a self-accounting foreign branch in JPK_KR_PD if that branch keeps them independently outside Poland.

This does not mean, however, that data relating to the branch is entirely irrelevant from the perspective of Polish tax obligations. The authority emphasised that the parent company should still keep records in a way that makes it possible to determine income, loss, the tax base and the tax due. If data relating to the branch affects Polish tax settlements, it should be properly reflected in the records of the parent company.

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Self-accounting branch – why does its status matter?

The concept of a self-accounting branch is crucial. It refers to an organisationally separated part of an entity that keeps its own accounting records and prepares separate financial statements.

In the case of foreign branches, this model often results from local legal and tax requirements. The branch operates in another country, is subject to that country’s accounting rules, and its data is subsequently included in the financial statements of the Polish parent entity.

From the perspective of JPK_KR_PD, it is important to distinguish between:

• accounting books kept by the Polish company,
• books kept independently by the foreign branch,
• branch data that may be necessary for preparing combined financial statements or tax settlements correctly.

The ruling issued by the Director of the National Revenue Information confirms that the obligation to prepare combined financial statements should not automatically be equated with the obligation to submit the full accounting books of a foreign branch in JPK_KR_PD.

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JPK_KR_PD should not lead to duplicate accounting for foreign branches

One of the most important practical effects of the new approach of the Polish tax authority is the reduced risk of creating duplicate accounting for foreign branches.

If the opposite approach were adopted, a Polish company could be forced to transform the local accounting books of a foreign branch for the purposes of the Polish JPK_KR_PD structure. In practice, this would require adapting the chart of accounts, tax markings, accounting data and reporting method to Polish requirements, even though the branch operates in a different legal system.

This approach could be particularly problematic for companies operating in several countries, using different accounting systems or functioning in structures where local branches have significant organisational independence.

The new ruling limits this risk. However, it does not release companies from the need to organise tax and accounting data in Poland. JPK_KR_PD still requires high-quality data, consistent records and correct allocation of information affecting CIT settlements in Poland.

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What remains the responsibility of the Polish company?

The favourable position of the Director of the National Revenue Information should not be understood as a complete exclusion of foreign branches from tax analysis. The parent company remains a CIT taxpayer in Poland and, as a rule, is subject to tax obligations on its worldwide income, taking into account the relevant provisions of the Polish Corporate Income Tax Act and applicable double tax treaties.

In practice, the company should still ensure that it:

• correctly determines whether the foreign activity constitutes a foreign permanent establishment within the meaning of the Polish Corporate Income Tax Act and the relevant double tax treaty,
• correctly identifies the method for avoiding double taxation,
• properly includes branch data in financial reporting,
• ensures the ability to determine the tax base in Poland,
• retains documentation explaining how branch data is reflected in tax settlements,
• assesses which data should be visible in the accounting books or records of the parent company, even if the full accounting books of the branch are not reported in JPK_KR_PD.

For this reason, preparation for JPK_KR_PD should not be limited to the technical generation of a file. In the case of groups and companies with international operations, it requires an earlier analysis of the accounting, tax and organisational model.

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Importance for companies preparing for JPK_CIT in Poland

JPK_KR_PD is part of a broader package of obligations commonly referred to as JPK_CIT. The Polish Ministry of Finance provides logical structures, technical specifications, information brochures and tools for preparing and submitting JPK_PD files.

For companies with foreign branches, the ruling of the Director of the National Revenue Information may be highly relevant when designing the reporting process. In practice, it is worth verifying:

• how the accounting of the parent entity is maintained,
• which branch data is included in the books of the Polish company,
• how the process of preparing combined financial statements works,
• whether branch data affects CIT settlements in Poland,
• whether the financial and accounting system can generate JPK_KR_PD within the required scope,
• whether documentation exists to justify the adopted approach.

Particular attention should be paid to situations where branch data is not reported as full accounting books but still affects the tax result or elements of the Polish company’s CIT settlement. In such cases, it may be necessary to properly reflect that data in auxiliary records, off-balance-sheet records or other documentation that demonstrates the correctness of the tax settlement.

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How does the new position relate to earlier doubts?

The issue of accounting books of foreign branches in the context of JPK_CIT had already raised significant doubts. We discussed them in more detail in the article: Accounting books of foreign branches and JPK_CIT – what do the Polish tax authorities expect?

The new ruling of the Director of the National Revenue Information resolves part of those doubts and gives taxpayers a stronger argument that the full accounting books of self-accounting foreign branches should not automatically be covered by the JPK_KR_PD reporting obligation.

However, this ruling should not be treated as a universal solution for all international structures. Individual tax rulings generally protect only the entity that obtained them and only within the scope of the factual situation described in the application. For other taxpayers, they may serve as an important interpretative guideline, but they do not replace an individual analysis of the company’s situation.

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Practical steps worth taking

Polish companies with foreign branches should use the new position of the Director of the National Revenue Information as a starting point for reviewing their accounting and tax processes. It is particularly important to determine where the boundary lies between the accounting books kept by the parent company and the books kept independently by the foreign branch.

In practice, it is worth analysing:

• whether the foreign branch is in fact self-accounting,
• under which regulations it keeps its accounting books,
• how its data is included in the combined financial statements,
• which branch data affects CIT settlements in Poland,
• whether the accounting policy clearly describes how branch data is recognised,
• whether the company has documentation confirming the adopted approach to JPK_KR_PD.

Such a review is important not only from a technical perspective, but also from an evidentiary one. In the event of a tax audit, the taxpayer should be able to explain why certain data was included in JPK_KR_PD, while other data remains outside the reporting scope as books kept independently by a foreign branch.

Implementing JPK_KR_PD requires a combination of accounting, tax and technology expertise. This is particularly important for companies operating internationally, which need to take into account both Polish reporting obligations and local accounting requirements applicable to foreign branches.

getsix® can support entrepreneurs and companies in analysing JPK_CIT obligations, assessing the scope of reportable data and organising accounting processes. Depending on the company’s needs, support may include accounting services in Poland, tax advisory in Poland and assistance with aligning finance and accounting processes with electronic reporting requirements.

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Summary: JPK_KR_PD and foreign branches

The individual tax ruling of 2 April 2026 confirms a favourable approach to JPK_KR_PD reporting for self-accounting foreign branches of Polish companies. The Director of the National Revenue Information stated that the obligation to submit accounting books under Article 9(1c) and 9(1e) of the Polish Corporate Income Tax Act should not cover books kept independently by such branches.

For businesses, this means a reduced risk that a Polish company will have to adapt the full local accounting books of a foreign branch to the Polish JPK_KR_PD structure. At the same time, the parent company should still keep records in a way that makes it possible to determine the correct CIT settlement in Poland.

The key practical conclusion is clear: the new position of the Polish tax authority does not eliminate analytical and documentation obligations, but it significantly clarifies the scope of reporting for accounting books of self-accounting foreign branches under JPK_KR_PD.

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Legal basis

• Individual tax ruling issued by the Director of the National Revenue Information on 2 April 2026, ref. no. 0111-KDIB1-2.4010.34.2026.2.EKB.

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