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This article answers the following questions:
- What is a Standard Audit File for Corporate Income Tax (JPK CIT)?
- Who and from what date will be subject to the JPK CIT reporting obligation?
- How will foreign businesses conducting activity in Poland be affected by the JPK CIT reporting obligation?
- What difficulties in preparing JPK CIT may arise?
Standard Audit File for Corporate Income Tax (Polish file name: JPK CIT), containing accounting data in electronic form, is a novel tool for improving the tax filing process in Poland. Up until recently, only active VAT payers have been required to file reports electronically, namely JPK VAT files. As soon as in 2026, the tax system will undergo an electronic revolution, which will also extend to accounting books.
Will every entity conducting business activity in Poland be subject to JPK CIT reporting obligation?
We know that in the first place, the new SAF-T requirements will apply to certain entrepreneurs. These are in a nutshell:
- from 1 January 2026 – CIT payers who generated gross revenue of more than 50 million euros in the preceding tax year;
- from 1 January 2027 – the remaining CIT payers.
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JPK CIT rules for foreign entities
The problem with JPK CIT occurs in a situation where a foreign entrepreneur conducts business activity in Poland, but a permanent establishment is created solely for tax purposes. An example of this can be a non-resident without a permanent establishment for tax in Poland engaged in commercial activity in cooperation with a sales representative. A similar case is a foreign entity engaged in construction or assembly business which extends the time of exemption from double tax set out in a relevant treaty.
For example, a non-resident carrying out construction and assembly works lasting longer than 12 months without establishing a branch in Poland does not have the obligation to keep accounts in Poland, as expressly arising from the Accounting Act.
Introduction of JPK CIT – The Ministry of Finance notices the problem, but does it solve it?
A lack of obligation to keep accounts in Poland does not relieve non-residents from the corporate income tax burden. In many cases, entities conducting business activities internationally do not keep accounts in Poland. In such instances, the data necessary for the preparation of the CIT return are imported from the accounting system of the foreign entity.
Preparing a JPK CIT file involves a wide range of data, including, but not limited to, journal entries, e.g. expense invoices broken down into net, gross, and VAT amounts, and the necessary elements for CIT calculation are in particular trial balance records broken down into expense and revenue accounts. Entities filing CIT in Poland do not receive full accounting records. For instance, detailed records concerning settlements or bank statements are not necessary for CIT filing. For this reason, the preparation of a JPK CIT file could be labour-intensive, and for entities with a huge number of accounting records, it can be said that it would be practically impossible.
The Ministry of Finance has paid special attention to the above tax problem and addressed this issue in an official e-mail, stating that in the absence of the obligation to keep accounts in accordance with the Accounting Act, the obligation to submit electronic accounting records, as set out in Article 9(1c) of the CIT Act, does not apply to such entities.
Introduction of JPK CIT – Summary
Summing up, the introduction of a Standard Audit File for CIT (JPK CIT) in Poland aims at improving the tax filing process. This obligation will be imposed in stages, first in 2026 on the largest CIT payers, then in 2027 on the remaining ones. The current standpoint of the Polish Ministry of Finance is as such: Entities conducting business activity in Poland without a permanent establishment are obliged to pay income tax in Poland but are not subject to the JPK CIT reporting obligation.
If you have any questions about JPK CIT, feel free to contact us. Our experts will be happy to assist you in preparing a Standard Audit File for Tax and clear up any doubts, sharing their broad knowledge with you. We can also discuss a different tax issue if needed.
