JPK_CIT: New reporting obligations

What is JPK CIT and what challenges does it pose for entrepreneurs?

From the beginning of 2025, Polish entrepreneurs, especially those operating on a larger scale, will face another challenge related to digitalization of taxes: the obligation to submit the CIT Single Control File (JPK CIT). JPK CIT, stemming from regulations introduced under the Polish Deal, is intended to further seal the tax system and increase the transparency of taxpayers’ settlements. It is advisable to understand now what this entails for your business and how to prepare for the upcoming changes.

New obligations starting in 2025. – what do they mean in practice? 1 January 2025 will mark the introduction of the obligation to keep books of account exclusively in electronic form and to annually send structured information contained therein to the tax authorities – specifically using the JPK CIT structure.

This means that JPK CIT will be sent without prior request from the tax authorities within the deadline for submission of the annual CIT-8 return and will consist of two modules: JPK_KR_PD and JPK_ST_KR. The aim is to give the tax authorities real-time access to core tax data, thereby enabling a more accurate and faster tax analysis and better selection of taxpayers for inspections.

Gradual implementation of JPK CIT

The obligation to submit JPK CIT will be staged, allowing businesses to adapt their systems and processes to the new requirements:

  • After 31 December 2024 – the obligation to submit JPK CIT will apply to the largest CIT taxpayers, i.e. taxpayers whose annual revenue exceeds the equivalent of EUR 50 million, and to tax capital groups.
  • After 31 December 2025 – the obligation will be extended to VAT taxpayers who are already obliged to submit JPK_VAT.
  • After 31 December 2026 – the obligation will apply to all other CIT payers, regardless of the company size.

Challenges related to the implementation of JPK CIT

For many companies, the implementation of JPK CIT can be challenging. This obligation calls for preparation of new procedures and IT systems that are capable of generating, processing and transmitting data in XML format as required by the regulation of the Ministry of Finance. In practice, this will entail the need to audit accounting processes and will necessitate the deployment of new IT solutions.

The process of adapting the accounting and technological systems can be time-consuming, so it is recommendable that it starts well in advance. Preventive measures, such as auditing and upgrading systems, can significantly mitigate the risk of reporting errors and facilitate seamless adaptation to new legal requirements.

The implementation of JPK CIT may also necessitate changes to internal processes in companies. In order to comply with the reporting requirements, companies may need to redefine their internal procedures. This may include training of accounting personnel, deploying new data management tools and increasing process automation. In addition, companies need to be prepared to keep abreast of legal changes and adapt to new regulatory requirements.

Our support

To help businesses adapt to these new requirements, Andersen offers comprehensive support, both in terms of legal and tax assistance and of technology. Our offer includes:

  1. Legal/tax/substantive support

One of the major challenges companies will face is the need to audit their accounting processes. This means reviewing current accounting and tax reporting procedures to ensure compliance with the new requirements. The audit may reveal the need to make changes not only to financial systems, but also to the way data is processed and stored. Accounting processes will need to be adapted to the requirements for the JPK CIT structure. As part of our support, we perform:

  • Audit of accounting processes – we carry out a pre-implementation analysis of accounting processes and data circulation in the company, along with identification of areas for optimization.
  • Mapping as required by the regulation – we carry out the process of mapping accounts as required by the regulation of the Ministry of Finance (including the published schema).
  • Verification of CIT calculation – we audit the adopted CIT calculation methodology to ensure its compliance with the new regulations.

In addition, our support may also include:

  • Delivery of workshops for the accounting department to improve their understanding of the new CIT obligations and requirements.
  • Preparation of a report with recommendations and practical guidance for process changes and changes in the legal and tax area, in particular such as:
  • Summary of the results of process audits,
  • Recommendations for changes in processes for the organization,
  • Recommendations regarding the account mapping process in accordance with the requirements provided for in the applicable legislation,
  • Summary of the impact of JPK_CIT on the organization,
  • Identification of processes, solutions and additional functionalities necessary to be implemented within JPK_CIT.

2. Technology support

Another challenge consists of adapting IT systems in companies. Financial and accounting systems must be prepared to generate and transmit data in the JPK CIT format. In many cases, this may entail the need to upgrade or purchase new IT solutions, integrated with the ERP system, which will enable seamless data reporting in accordance with the new legal requirements. Inadequate adaptation of IT systems may result in the inability to file on time, which may lead to sanctions.

In terms of technological support, Andersen, in cooperation with its IT partners, offers tools to effectively implement or adapt accounting processes to the latest legal requirements.

In this respect, our support includes:

  • Technical infrastructure audit – review and verification of the technical infrastructure with a view to adapting it to the requirements of JPK_CIT, helping to identify areas in need of upgrading.
  • IT tools integrated with the ERP system – we offer IT tools to generate the JPK CIT file schema in compliance with the legal requirements.
  • Implementation and post-implementation support – we provide ongoing support both during and after the implementation of IT systems – also for IT work carried out by third parties.

You are welcome to contact our specialists at Andersen Tax & Legal Poland. We will help you to fully adapt to the upcoming legislative changes by providing comprehensive support at every stage of the CIT JPK implementation.

KONTAKT

Aleksandra Kalinowska Partner, Warsaw

E: aleksandra.kalinowska@pl.Andersen.com
T: +48 22 690 08 70
M: +48 724 440 693

Elżbieta Lis Partner, Katowice

E: elzbieta.lis@pl.Andersen.com
T: +48 32 731 68 58
M: +48 664 948 038

Joanna Marciniak Senior Manager, Warsaw

E: joanna.marciniak@pl.Andersen.com
T: +48 22 690 08 88

Szymon Chyra Manager | Tax advisor, Katowice

E: szymon.chyra@pl.Andersen.com
T: +48 32 731 68 50

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