In a last PwC’s alert dated February 27, 2024, we described the increased interest of the National Tax Administration (in Polish Krajowa Administracja Skarbowa, so called "KAS") in terms of data reported within the framework of the Standard Audit File /SAF-T/ ("JPK"). This trend not only indicates the growing role of digital tools in tax audit processes, but also a transforming approach in terms of supervising the correctness of tax settlements.
According to the data steaming from the Polish Supreme Audit Office (in Polish Najwyższa Izba Kontroli, so called “NIK”) report, in the first half of 2022, the heads of tax and customs-tax offices received 6309 JPK upon request structures within tax and customs-tax audits, which presents an increase of 2292 compared to the first half of 2021. Moreover, the most frequently received structure in both of these periods was the sales invoices file (JPK_FA), which may indicate particular interest of tax authorities in sales transactions.
The abovementioned trend is in line with the recommendations of the Deputy Head of KAS, who in June 2022 ordered an increase in JPK upon request usage. This is an indication that the tax authorities intend to continue developing digital tools for audit processes.
PwC Studio tax service has obtained the latest data for 2023 from the Ministry of Finance in terms of the number of collected JPK structures within the inquiry activities, tax audits and customs-tax audits. Below, we present the latest data compared to previous periods and point out the most common errors the taxpayers face in terms of generating JPK upon request structures.
Data analysis
The data collected for 2020 - 2023 indicates that KAS authorities increasingly request submission of JPK files. The number of JPK file collections for tax audits and customs-tax audits doubled from 7236 in 2020 to 14976 in 2023. The details are shown with the help of the following graph.
Graph No. 1
Analyzing the data presented in the graph below, in the first half of 2021, during tax audits and customs-tax audits, the tax authorities received a total of 4007 JPK upon request files, while in the first half of 2023 this number has increased to 7256 files, indicating an increase of 81.08% compared to the first half of 2021.
Graph No. 2
Looking at the data shown in Graph 3 for 2020 and 2023 in terms of the number of JPK collections during tax audits and customs-tax audits, a significant increase in the number of collections can be seen in 2023 compared to 2020.
For example, a significant increase was recorded for the JPK_FA structure. In 2023, the number of requests for submission of this structure amounted to 4484 - more than double compared to 2020 (2122). Similar trends may be observed in the case of other structures, such as JPK_KR, JPK_MAG and JPK_WB, for which the number of submission requests has increased significantly in all categories. Particularly, JPK_WB structure recorded an almost double increase in the number of requests, growing from 1507 in 2020 to 2701 in 2022.
Graph No. 3
JPK upon request vs. inquiry activities
It should be pointed out that JPK upon request is a tool of the fiscal authorities used not only for tax audits and customs-tax audits. KAS authorities are authorised to request submission of JPK also during the inquiry activities.
In total, in 2023, the number of collected JPK upon request structures during the inquiry activities amounted to 5739, which proves that JPK is a tool intensively used by tax authorities for monitoring and controlling the correctness of tax settlements of taxpayers. The details are shown in the following graph.
Graph No. 4
What are the challenges in the JPK file generation?
The process of preparing and submitting data in JPK structures can be challenging for taxpayers, requiring extensive knowledge and in-depth analysis of .xml files, as well as the appropriate configuration of financial and accounting systems. In order to illustrate these issues and their scale, we present below a summary of the most common difficulties associated with the generation of JPK upon request:
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Issues related to JPK_FA |
Issues related to JPK_KR |
Issues related to JPK_MAG |
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Business data validation |
Incorrect reporting of sales values (currency conversions, rounding of amounts, use of VAT rates) |
Incorrect verification of accounting entries (date, description, numbering, amounts, assignment of accounts) |
Incorrect classification of warehouse movements that are not related to warehouse documents, such as inventory or write-offs |
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Completeness of data |
Missing mandatory fields (e.g. invoice number, date of issue, taxpayer identification data, type of invoice) |
Inconsistency of data in different sections of JPK_KR (Journal vs accounts, balances vs turnover) |
Incorrect identification of warehouses (effects number of JPK_MAG files) |
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Consistency with the source documents |
Data exported from the accounting systems inconsistent with the invoices (e.g. inconsistency in date of sale/date of issue) |
Inconsistency of JPK_KR data with other JPK structures or tax returns |
Inconsistency of data in JPK_MAG file with warehouse documents (e.g. correction, cancellation, duplication or other changes in warehouse data) |
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Integration of systems |
Difficulties in reporting all types of sales invoices in the JPK_FA file (e.g. lack of proper system configuration in the case of foreign currency or advance invoices) |
Difficulties in reporting all mandatory elements in JPK_KR according to regulations, e.g. incomplete translation of descriptions, lack of journal, lack of chronological order in journal entry numbers, lack of turnover for the period in trial balance (ZOiS), incorrectly imported opening balance (e.g. balance at the date of report generation instead of balance at the beginning of the financial year), lack of category codes and subcategory codes for individual accounts in trial balance (ZOiS) |
Difficulties in reconciling warehouse data with accounting, tax or other JPK structures |
How can we help
JPK
PwC offers support with JPK by a dedicated Taxolite application which, along with our methodology and experience, makes it possible to meet the legal requirements and guidelines of the Ministry of Finance. Taxolite application has been developed to enable the implementation of tax reporting even in the most complex system structures. It can be integrated with other data sources and ERP systems, without the need of changing system environments. Taxolite allows taxpayers to: collect, verify, generate, test and send JPK upon request.
More information about the Taxolite application.
At the same time, PwC offers assistance in testing JPK files for their technical and substantive correctness using a dedicated SAF-T data tester. The application allows verifying the xml file against the structures: JPK_FA(3), JPK_FA(4), JPK_KR(1), JPK_MAG(1), JPK_V7M(1), JPK_V7M(2), published by the Ministry of Finance. The tool identifies technical irregularities verification of the consistency of reported data with tax requirements.
More information about the SAF-T data tester.
KSeF
In the face of upcoming changes in tax regulations introducing the mandatory use of electronic invoicing through the National e-Invoicing System (in Polish Krajowy System e-Faktur, so called “KSeF”), entrepreneurs are facing the obligation to adapt their accounting processes to the new requirements. In response to the upcoming changes, PwC has developed a dedicated Taxolite e-Invoicing Tool that allows full and flexible adaptation to the requirements minimising the need to adapt ERP or billing systems as well as reducing the need to change key processes or systems already operating in the company.
In addition, PwC offers a tool for verifying the correctness of structured invoices with KSeF Data Tester. The application includes a set of technical and business tests developed by PwC experts to ensure FA(2) schema compliance The business verification verifies the invoice's compliance with tax requirements, including mathematical and logic tests, as well as a number of other tests tailored to various transactions that may potentially occur.
More information about tools for e-invoicing.
At the same time, PwC is providing a range of services to adapt to the upcoming changes. In particular, PwC's support can consist of reviewing and mapping the current issuing and receiving invoices processes. The analysis carried out in this way will also identify tax risks associated with the current invoicing model. In addition, we can support clients as part of the construction, implementation and testing of their own technical solutions, and as part of the reconstruction of systems in the area of business and technical requirements.
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