For most businesses, the new reporting obligations represent an evolution of the existing regulations. However, we must remember that many companies keep their accounting ledgers using some foreign accounting software, often outside Poland. Given that JPK_KR files have previously been transmitted only upon request from authorities, many businesses have not secured the option to generate these files in their systems. This will be a revolution for them, as the work must essentially start from scratch. 

On the other hand, as Piotr LISS, Tax Partner at RSM Poland, notes in an interview that was also featured in Forbes magazine, many previous JPK_KR implementations have been flawed, and the generated files fail to meet current JPK_KR_PD requirements.

Are companies ready to align their reporting with JPK_CIT?

Piotr LISS: 

Many businesses have already started their preparations, and ERP software providers are working to develop modules than will ensure compliance. However, the technical aspect isn't everything – we have noticed that many companies need to make changes to their accounting methods, descriptions, and charts of accounts. The technical side is just as important as the proper implementation of accounting processes.

Which businesses should analyse their systems in the light of new obligations?

Piotr LISS: 

Companies utilising local financial and accounting systems will, in most cases, stay away from the revolution that will affect organisations being part of international corporations. These often have shared service centres located outside Poland, running on global systems where making any changes is difficult. At the same time, given that it is the management board in Poland, not the head office, that is accountable for failure to submit a JPK_CIT file, introducing changes is often not given sufficient priority.

Is it possible to generate a JPK_CIT file from any system?

Piotr LISS: 

If the system allows users to export data to Excel – then yes, JPK_CIT can be generated using tools that convert data to the required format.

Data quality and its compatibility with Polish reporting frameworks is, however, a whole subject on its own. In systems running under, for example, US GAAP, the transition to local reporting standards often takes place in MS Excel, so reporting will not fully meet statutory requirements. Of course, taxpayers can use some external software, but this will only be a makeshift solution, so it's worth seeking the support of tax advisors.