CIT taxpayers will soon be obliged to submit their CIT settlements to tax authorities in a form based on the current JPK-KR structure (so-called JPK-CIT). The draft regulation imposing additional obligations on the taxpayers in this regard was published on November 29, 2023 on the website of the Government Legislation Center. The Ministry of Finance has also shared a new logical structure for JPK-KR. In practice this means that the tax authorities will be able to select entities for a tax audit even more effectively. Taxpayers have little time left to prepare for these changes.
The proposed new logical structure presenting data for reporting contains significantly more mandatory elements than the present JPK-KR structure. Additionally taxpayers will have to face numerous system, process and technical challenges.
The introduction of legislative changes will require entrepreneurs to adjust their financial and accounting systems and/or implement new IT solutions in order to prepare for the upcoming requirements. It is also necessary to review the correctness of CIT settlements and the CIT calculation process. Taxpayers who fail to comply with the new requirements may encounter problems submitting JPK-CIT and risk a dispute with tax authorities who may question the correctness of CIT settlements. For the first group of taxpayers the so-called JPK-CIT must be submitted for 2025 which may entail (depending on the technological solutions used) necessity to adjust systems as soon as the booking process begins at the beginning of 2025. In this case taxpayers will have to use their time in 2024 to prepare for the changes..
According to the draft regulation taxpayers will have to additionally supplement the books with, in particular, the following:
- identification data of the taxpayer's contractor;
- at the Journal level for invoices issued in KSeF - the number identifying the invoice or correction invoice in the National e-Invoice System (the so-called “KSeF”);
- tags identifying booking accounts, at the level of the trial balance (“ZOiS”) node, reported according to the entity-specific dictionary of tags identifying booking accounts (defined by the regulation);
- data confirming the acquisition, creation or removal from the records of a fixed or intangible asset including among others:
- invoice identification number in KSeF, if assigned (for invoices constituting accounting evidence);
- determination of the type of proof of acquisition, creation or removal from the records.
- the amount, type and type of difference between the balance sheet result and the tax result - according to the justification of the draft regulation, this means the obligation to report:
- tax expenses that are not a balance sheet expense,
- balance sheet costs that are not a tax expenses,
- tax revenue that is not balance sheet revenue,
- balance sheet income that is not taxable income,
- non-taxable income,
- costs related to non-taxable income,
- tax-free income.
The draft regulation is currently under review and is available on the pages of the Government Legislation Center via the link. In turn, the proposal for the new logical structure of JPK-KR is available at the link. Until December 29, 2023 the Ministry of Finance is conducting a tax consultation on the new logical structure which means that the final version may differ from the proposed one.
Our team is prepared to support you in making preparations for these changes.
We will keep you updated on further progress of the work.
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