End of the Obligation to Publish a Tax Strategy and Upcoming KSeF and JPK_CIT Regulations

Under the Act of 25 June 2025 amending the Corporate Income Tax Act (Journal of Laws of 2025, item 1074 as amended), Article 27c of the CIT Act has been repealed and the obligation to prepare and publish information on the implemented tax strategy has been abolished. The Act entered into force on 7 August 2025.

Repeal of Article 27c of the CIT Act and Transitional Provisions

The repeal of Article 27c of the CIT Act results in the removal of the obligation to prepare and publish information on the implemented tax strategy. Taxpayers have also been released from the obligation to provide the head of the tax office with information on the website address where the document was made available.

In light of the amendment, obligations related to tax strategies whose deadlines fell after 6 August 2025 cease to apply to taxpayers. This means that entities whose tax year coincides with the calendar year will not be required to prepare and publish a tax strategy for 2024 or for subsequent years.

Importantly, if the deadline referred to in repealed Article 27c(4) of the CIT Act expired before the date of entry into force of the Act, then, pursuant to Article 2 of the amending Act, all pending proceedings regarding the imposition of a financial penalty (repealed Article 27c(8) of the CIT Act) are discontinued, and no new proceedings in this respect will be initiated.

Publication of the Tax Strategy on the Website for Previous Years

The repeal of Article 27c of the CIT Act also entails the abolition of the obligation to make information available on the website for individual years (repealed Article 27c(6) of the CIT Act). Consequently, the obligation to ensure access to information posted on the website for previous years has been removed. It is worth noting that the amending Act itself does not address the issue of ensuring access to documents for previous years; however, the intention of the legislator was expressed in the explanatory memorandum to the Act:

“The repeal of Article 27c of the CIT Act will be tantamount to the abolition of the obligation to make information available on the website for individual years (Article 27c(6)). Under the existing provisions, information once posted on the website is to be available to interested parties in subsequent years. Thus, after the entry into force of the Act, the obligation to ensure access to information posted on the website for previous years will also be abolished.”

Recommendations

The amendment is a favourable change for taxpayers, as it eliminates an obligation which, in the opinion of many entities, was merely an additional reporting burden that did not bring real value to the tax system. However, it should be remembered that although the publication requirement has been repealed, tax risk management processes and internal procedures themselves remain crucial for the proper functioning of organisations and for effective cooperation with the National Revenue Administration (KAS).

In light of upcoming regulations – in particular those concerning KSeF and JPK_CIT – many companies will have to adapt their procedures, document flows and internal tax processes. If your organisation needs support in implementing these changes, preparing appropriate procedures or assessing operational readiness, we remain at your full disposal.