Ministry of Finance has no plans to postpone JPK CIT implementation deadline

2024 / 03 / 20

The implementation of mandatory JPK_CIT system is the next stage in the process of digitization of taxpayer-fiscal authorities interaction. This is a key part of an extensive strategy aimed at digitization of tax settlements, as adopted by the Ministry. According to the new wording of the CIT Law which is to take effect on January 1, 2025, taxpayers will be obliged to file JPK_CIT annually in the period of 3 months after the fiscal year-end.

At the last reconciliation meeting, the Ministry informed they had no plans to postpone the entry into force of the new regulations. Thus, CIT payers will be required to submit their first reports on the following dates:

tax capital groups (fiscal unities) and the largest taxpayers (falling within the competence of the First Mazovian Tax Office) – for the fiscal year beginning after December 31, 2024 (in practice, they will be obliged to adjust the tax books as early as 2025);
taxpayers required to file JPK VAT records – for the fiscal year beginning after December 31, 2025 (in practice, their tax books will have to be adjusted in 2026), at which time the reporting requirement will first arise for PIT taxpayers submitting JPK VAT records;
other VAT taxpayers – for the fiscal year beginning after December 31, 2026 (in practice, the adjustment of their tax books will have to be made in 2027), on the same date the new reporting obligations will extend to other PIT taxpayers.

The new files will be developed on the basis of the currently existing “on-demand” logical structures – JPK_KR. At the same time, the implementing legislation that has been published under the new regulations provides for introduction of the following:

additional markers (tags) identifying ledger accounts used by taxpayers in the JPK_KR structure;
additional data for reporting.

At a conference held on March 1, 2024, the Ministry additionally informed of:

simplification of certain elements of the reporting obligation (including the abandonment of the obligation to provide counterparty details or limitation of KSeF numbers to be reported);
optional reports on selected data in the first year of the new regulations;
separation of fixed-asset records into a separate schema.

On March 14, 2024, the Ministry published two draft structures: JPK_KR_PD and JPK_ST, and invited taxpayers to public consultations in this respect.

The Ministry holds the view that now is the time to consider the relevant steps to verify JPK_KR files prepared under the current regulations. In addition, according to the draft schema it is necessary to check what adaptation measures are necessary to comply with the new obligations.

Our experts will be happy to answer your potential questions and provide all the required support in the process of preparation for complying with the new duties.

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