JPK CIT (SAF-T concerning CIT) – When will submitting CIT returns in the form of a Standard Audit File be mandatory?

From this article, you will learn:

• How to prepare the company for the obligation to submit JPK CIT?
• Who will be obliged to submit JPK CIT?
• What information must be included in the Standard Audit File for the whole year?

The works on the standardization and full digitization of tax filings in Poland are still in progress. As we know, it is an element of a comprehensive strategy of the Ministry of Finance, which aims to strengthen the system and facilitate communication on the taxpayer-authorities line. By default, the changes are to make it more efficient for officials to select candidates for tax audit from among taxpayers. But what does it mean for entities conducting business activities in Poland? Does the new SAF-T covering the entire year mean only trouble for taxpayers, or does it offer them any real benefits?

In accordance with the CIT Act, which will come into force on 1 January 2025, the obligation to submit a Standard Audit File concerning CIT will arise every year within the time limit for filing tax returns.

During the first stage, the obligation to submit JPK CIT will be imposed on the so-called large CIT payers, i.e. companies whose revenue exceeded EUR 50 million and tax capital groups. For taxpayers from this group (whose tax year begins when the new provisions of the CIT Act take effect), it means that the first CIT return in the form of SAF-T will have to be filed by 31 March 2026. As a result, their accounting systems will have to be aligned with the requirements of the Ministry of Finance, both in terms of data structure and the bookkeeping method. 

Realistically speaking, there is not much time left to implement these changes. 

How to prepare your company for the changes caused by the JPK CIT regulations?

At the time being, the regulations concerning JPK_KR apply in Poland, under which taxpayers are obliged to submit their accounting books in the form of a Standard Audit File to tax authorities. These provisions apply only to the taxpayers who keep their accounting records digitally. It is worth noting that the present legal status clearly specifies the circumstances under which tax authorities may request the taxpayer to submit JPK_KR. It can only happen during verification activities or tax proceedings.

The new regulations, which will apply from 1 January 2025, will greatly extend the competences of tax authorities – annual JPK CIT files will have to be submitted to officials without their prior request. It means that taxpayers may be audited without being notified beforehand. 

In addition, taxpayers should adjust their financial management software and the bookkeeping method so that they comply with the requirement of submitting JPK CIT files in the form indicated by the Ministry of Finance.

What information will be necessary in JPK CIT?

With respect to the scope of mandatory information provided by taxpayers, the provisions adopted as part of the Polish Deal currently apply. And as of now, there are no sings that they will have been amended before the entry into force of the JPK CIT regulations, i.e. 1 January 2025. 

However, the Ministry of Finance, in its draft regulation of 20 November 2023 (published on 29 November 2023), imposes on taxpayers additional requirements regarding the information which must be provided in the Standard Audit File.

In the said draft regulation, the Ministry of Finance puts forward the following changes:

• adding to the JPK_CIT structure tags identifying the accounts used by entities with the reporting obligation,
• introducing JPK_KR changes within the area concerning this information.

In the statement of reasons for the draft regulation, the Ministry of Finance explains that the above changes are brought about by the necessity to compare submitted financial statements with data contained in JPK_VAT and with information derived from the National e-Invoicing System (KSeF).

In accordance with the draft regulation in question (in its original version), taxpayers who are obliged to submit JPK_CIT files must include the following data in their accounting records kept digitally:

• particulars of the taxpayer's trading partner;
• number of invoice (or correction invoice) enabling the identification of the document in KSeF (if the invoice is an accounting document);
• tags identifying the accounts (in line with the dictionary of tags set out in the draft regulation);
• data confirming the acquisition, production, or removal from the register of a tangible asset or intangible asset;
• amount, kind, and type of difference between the accounting result and tax result. In accordance with the statement of reasons for the draft regulation, the above information should make particular records in the accounting books more specific.
• for taxpayers levied with flat-rate tax on the income of companies – the amount and kind of taxable income.

Which entities are obliged to submit JPK CIT files?

The adopted transitional provisions introduce the obligation to submit JPK_CIT in stages, depending on the size of the entity and the date on which its tax year begins. The first group are the so-called large CIT payers.

• Entities which start their tax year after 31 December 2024 and whose revenue exceeded EUR 50 million or equivalent in the preceding tax or fiscal year, or which belong to a tax capital group, will be obliged to submit JPK_CIT as part of their annual tax return already in 2026.
• Other VAT payers will be obliged to submit JPK_CIT records (in addition to JPK_VAT) after 31 December 2025.
• After 31 December 2026, the obligation to submit JPK_CIT will be imposed on all CIT payers.

How to prepare the company for the obligation to submit JPK CIT?

Realistically, there is not much time for large taxpayers to prepare for the entry into force of the JPK CIT regulations. Worse still, the biggest challenge seems to be the implementation of system changes – both in terms of IT and bookkeeping – in such large entities. 

In order to adjust a company's system to the provisions contained in the regulation, which is still under development, profound changes in the bookkeeping process may be required. Reorganization of both the general ledger and subsidiary ledgers might be necessary.
To make sure that the process will take place in a professional and effective manner, it is advisable to take advantage of the services provided by qualified experts.