On the website of the Government Legislative Center (Polish:RCL) the Ministry of Finance published information on the submission for urgent publication in the Polish Journal of Laws of the regulation regarding additional data that should be included in the so-called JPK-CIT (SAF-T for corporate income tax purposes).
The regulations imposing obligations concerning JPK-CIT, including this regulation, come into effect on January 1, 2025. There is not much time left, and there are many tasks to be completed. The regulation is awaiting publication.
Regulation submitted for publication differs from previous drafts as it incorporates amendment proposals made by the Legal Committee. The previous version excluded the requirement to submit data from the fixed assets register in the first year starting after December 31, 2024 (which was interpreted as a lack of obligation to submit JPK_ST_KR). However, the final version no longer includes such a provision. The wording of the remaining exemption refers to additional data, not to the register itself. Therefore, the final content of the regulation indicates the obligation to send JPK_ST_KR also in the first year for which JPK-CIT will be submitted. Additional explanations regarding this matter may be included in the informational brochure for the new JPK structures, which is expected to be published by the Ministry of Finance soon.
Regardless of the changes in the regulation itself, the first taxpayers will submit JPK-CIT for the fiscal year beginning after December 31, 2024. This applies to entities with tax revenues exceeding EUR 50 million and tax capital groups. In practice, JPK-CIT comprises two structures:
1) JPK_KR_PD (primarily covering the trial balance, records on accounts, and so-called tax markers indicating how the operations have been recognized for CIT purposes), and
2) JPK_ST_KR (registry of fixed assets and intangible assets, containing specified data – this is the structure referred to in the earlier mentioned uncertainty).
Taxpayers have a lot of work ahead of them. As PwC, we support clients by verifying tax settlements concerning JPK-CIT or offering technological support (including the Taxolite tool). We encourage you to schedule a meeting with our experts.