The Polish Supreme Audit Office (in Polish Najwyższa Izba Kontroli, so called “NIK”) on February 9th, 2024 has published a report outlining the results of proceedings conducted by the National Tax Administration (in Polish Krajowa Administracja Skarbowa, so called "KAS") in terms of their accuracy and effectiveness. The report states that the number of performed tax audit activities has significantly increased. In addition, the report confirms a large increase in requests to taxpayers for submission of data from tax books and accounting evidence in the form of the Standard Audit File ("JPK") in the course of KAS audits.
KAS authorities, in the course of tax proceedings, may request taxpayers to submit data in a predefined electronic format (SAF-T/JPK) to the following extent:
- JPK_KR - accounting books,
- JPK_WB - bank statements,
- JPK_MAG - warehouse,
- JPK_FA - invoices,
- JPK_PKPIR - tax revenue and expense ledger,
- JPK_EWP - revenue register,
- JPK_FA_RR - for VAT RR invoices (flat rate farmers).
Please note that the obligation to submit JPK on tax authorities request firstly covered the so-called large enterprises, i.e. as early as July 1, 2016. For small, medium and micro-entrepreneurs, the requirement is effective as of July 1, 2018. Further, the JPK_FA_RR structure was introduced as of September 1, 2019.
JPK vs. tax audits
The report has been published on the NIK’s website (nik.gov.pl) outlining the results of proceedings conducted by KAS authorities in terms of their accuracy and effectiveness. The report shows that the number of performed tax audit activities has significantly increased. In addition, the report confirms a large increase in requests to taxpayers for submission of data from tax books and accounting evidence in the form of the JPK /SAF-T in the course of KAS audits.
For example, in the first half of 2021, in the course of tax audits carried out by heads of tax offices and heads of customs and revenue offices, 4017 JPK files on the request were received, while in the first half of 2022, the number of JPK files on the request in the same audits amounted to 6309, which is an increase of 57.05%.
Further, the NIK report revealed that the total number of submitted JPK files on the request in the course of tax audits activities in 2021 amounted to 10,688, which compared to 2020 (where the number was 7236) indicates an increase of 47.71%.
The report also shows that the most often requested JPK files on the request was a structure dedicated to sales invoices JPK_FA. Thus, for 2020, 2122 such files were received, where in 2021 there were already 3051 files, resulting in a year-to-year increase of 43.78%.
Taking the above into consideration the conclusion is that KAS are increasingly using JPK files on the request in the course of tax audits.
It is also worth noting that in June 2022 the Deputy Head of KAS recommended increasing the use of on the request JPK structures in ongoing proceedings. Which can be treated as confirmation of the tax authorities intentions regarding a wider use of JPK in the future tax audits.
Our experience
Our experience in supporting legitimate business in the course of tax audits confirms that requests to submit JPK is a standard practice of the authorities in almost every audit case.
Based on our experience it should be assessed that a most frequent reason for the inability to prepare of JPK arises from a lack or insufficient amount of data in taxpayers accounting systems. Which consequently results in the inability to collect the necessary information for the JPK preparation that meets all the necessary requirements.
Moreover, taxpayers report a lack of or insufficient functionality of the tools they use to generate the requested files with accordance to structure published by the Polish Ministry of Finance.
How can we help
PwC has a dedicated Taxolite application, methodology and experience in JPK projects, enabling us to meet the requirements of the law and the guidelines of the Ministry of Finance in this regard. We also support our clients by providing the service of generating JPK on the request files.
If you already have a solution for JPK
The scope of our support may include:
- JPK file testing - consisting of technical compliance and substantive testing,
- verification of data mapping to JPK structures.
If you are looking for a different kind of support
We offer:
- consulting on the interpretation of JPK requirements,
- JPK workshops or consultations on JPK requirements and possible reporting concepts,
- creation and testing of JPK structures (accounting books, bank statements, warehouses, invoices).
The scope of our support may also include:
- JPK generation service - both as part of a permanent contract and in the event of tax audits requests,
- audit of JPK files - consisting of technical compliance and substantive testing,
- support for mapping data from' IT systems onto JPK structures,
- analytical support in the implementation of customer solutions dedicated to JPK, including solutions in ERP systems (SAP, Oracle, MS Dynamics).
When preparing and testing files for our clients in the JPK structure, we cooperate with PwC's Tax Litigation Team, which can provide you with comprehensive support in the course of tax proceedings. If you have any concerns or questions about the above information, please contact us.
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