Further changes in the provisions implementing the JPK_CIT file

At the end of November 2023, the Minister of Finance published a draft Regulation on additional data with which the books to be submitted to the tax authorities under the Corporate Income Tax Act must be supplemented. The provisions introducing amendments to JPK_CIT contained in the said bill are to take effect on 1 January 2025. 

What data should be included in the JPK file?

The draft regulation in question sets out the scope of additional data with which the JPK_CIT file must be supplemented. In accordance with the bill published by the Minister of Finance, the books submitted to the tax authorities will have to be supplemented with the following data:

1. particulars of the taxpayer’s trading partner and his, her or its Tax Identification Number (NIP) (if assigned), and:
   1. First name and surname (if the trading partner is a natural person not conducting business activity),
   2. First name and surname together with additional wording which is part of the entrepreneur’s business name (if the trading partner is a natural person conducting business activity) or the full business name of the trading partner (in other cases);
2. in the case of invoices being accounting documents – the number identifying the invoice in the National e-Invoicing System (if assigned);
3. tags identifying the accounts, as per the dictionary of tags identifying the accounts for the following entities:
   1. banks – set out in Annex 1 to the Regulation,
   2. insurance companies and reinsurance companies – set out in Annex 2 to the Regulation,
   3. the entities referred to in Article 3(2) of the Public Benefit Activity and Voluntary Work Act of 24 April 2003 (Journal of Laws of 2023, item 571) preparing financial statements in compliance with Annex 6 to the Accounting Act of 29 September 1994 (Journal of Laws of 2023, items 120, 295 and 1598) – set out in Annex 3 to the Regulation,
   4. investment funds – set out in Annex 4 to the Regulation,
   5. brokerage houses – set out in Annex 5 to the Regulation,
   6. credit unions – set out in Annex 6 to the Regulation,
   7. other entities – set out in Annex 7 to the Regulation;
4. data confirming the acquisition, production or removal from the register of a tangible asset or intangible asset:
   1.  in the case of invoices being accounting documents – the number identifying the invoice in the National e-Invoicing System (if assigned),
   2. information on the type of document confirming the acquisition, production or removal from the register,
   3. tax identification number of the taxpayer’s trading partner;
5. the amount, kind and type of difference between the accounting result and tax result;
6. the amount and kind of taxable income with reference to taxpayers levied with flat tax on the income of companies.

Note – the draft regulation is currently at the evaluation stage, therefore, its final content may be different.

When will the regulation concerning JPK_CIT take effect?

As a reminder, the date on which the new so-called JPK_CIT obligations will be imposed on the taxpayer depends on the taxpayer’s revenue. The provisions will be thus implemented gradually and apply in the tax years beginning after:

• 31 December 2024 – for large CIT payers (revenue above EUR 50 million) and tax capital groups;
• 31 December 2025 – for other CIT and PIT payers obliged to submit JPK_VAT;
• 31 December 2026 – for all the remaining taxpayers.