Mandatory JPK CIT (SAF-T for CIT) reporting in Poland – practical implications for international groups

The article by PKF expert (Agnieszka Chamera - Managing Partner of PKF Tax&Legal, Tax Advisor).

From January 2025, Poland will implement a new requirement for corporate income tax (CIT) reporting in the form of a structured XML file – known as JPK CIT (standard audit file for corporate income tax). This obligation is part of a broader digitalisation strategy pursued by the Ministry of Finance to increase transparency and automate tax oversight.

The JPK CIT structure includes two key components:

• JPK_KR_PD – general ledger data mapped to tax calculations
• JPK_ST – register of fixed assets and intangible assets.

Implementation timeline and scope

The roll-out of the obligation is phased as follows:

• from 1 January 2025 for large entities, i.e. those that in 2024 had net revenues exceeding €50 million;
• from 1 January 2026 for CIT taxpayers who are required to submit JPK_VAT (SAF-T for VAT); and
• from 1 January 2027 for all remaining CIT taxpayers.

Entities subject to this obligation must ensure that their systems, data structures and internal procedures allow for the generation of compliant XML files reflecting both accounting and tax data.

Key risks and challenges

From a practical point of view, the implementation of JPK CIT presents several challenges – particularly for entities operating within international capital groups. In many cases, accounting books and fixed asset records are maintained outside Poland, using global ERP systems that are not adapted to Polish reporting standards or XML structures.

Common issues include:

• incompatibility of accounting systems with Polish XML schemas (XSD);
• difficulties in mapping group-level accounts to local tax categories;
• risk of data inconsistencies and reporting errors due to system localisation gaps; and
• increased audit exposure, resulting from the analytical capabilities of structured data.

Additionally, the new reporting regime often requires procedural changes and thorough documentation of the CIT calculation process and data sources.

Significance of the individual tax ruling

Further clarification is provided in the individual tax ruling dated 21 February 2025, No. 0114-KDIP2-2.4010.714.2024.1.PK issued by the Director of the National Tax Information in Poland. The ruling states that the JPK CIT obligation applies only to taxpayers who maintain their accounting books in Poland. This is particularly relevant for international structures where Polish activities are conducted via a tax permanent establishment without forming a registered branch or representative office.

The ruling indicates:
‘Given the above, in cases where only a tax permanent establishment is created in Poland without establishing a branch or representative office – as is the case in this matter – and therefore without the obligation to keep accounting books under the Accounting Act, fulfilling the obligation under Article 9(1c) of the CIT Act is not justified. The absence of an obligation to maintain accounting books in Poland under the Accounting Act means they cannot be kept using computer programs nor submitted to the relevant tax office.’

The ruling also refers to article 9(1d)(3) of the CIT Act, which exempts taxpayers maintaining simplified revenue and expense records from the JPK CIT obligation. Although the method for maintaining such records is not precisely defined, the authorities suggest that under these circumstances, simplified records are sufficient for proper tax calculation and therefore exempt the taxpayer from the JPK CIT requirement.

Recommendations for taxpayers

To ensure readiness for JPK CIT implementation, companies should consider:

1. Tax and data readiness review – Assessing the completeness and quality of source data
2. System capability analysis – Verifying the ability to export data in XML format
3. Chart of accounts mapping – Aligning group structures with JPK tagging
4. XML file testing – Both technically and substantively
5. Procedure alignment – Documenting accounting and tax compliance procedures
6. Engaging local advisors, particularly if bookkeeping is maintained abroad.