This article answers the following questions:

  • What is reported in the JPK CIT file?
  • What are JPK tags?
  • How can a company implement JPK CIT reporting?

The Standard Audit File for Tax (JPK CIT), an electronic format for submitting data related to Polish corporate tax settlements, is designed to enhance taxpayer transparency. While one of the advantages of this system is the simplification of certain procedures within companies and public institutions, business owners should be aware that such standardised reporting enables tax authorities to analyse data more swiftly and detect discrepancies more easily—potentially leading to an increase in tax audits. So how can one correctly generate a JPK CIT file and avoid penalties or visits from the tax office?

 

What is the Standard Audit File for Tax (JPK CIT) and why was it introduced?

JPK CIT is a standardised tax reporting system that provides the Polish tax administration with access to detailed accounting data from taxpayers. The system comprises two key structures: JPK_KR_PD and JPK_ST_KR.

The implementation of JPK CIT aims to:

  • tighten the Polish tax system,
  • automate tax audits,
  • streamline the process of selecting entities for inspection.

Additional data used in the JPK_KR_PD and JPK_ST_KR structures

 

JPK_KR_PD – the Extended General Ledger

The JPK_KR_PD schema enhances the previously used JPK_KR structure by incorporating data required for corporate income tax reporting. The revised file includes:

  • Identification data – details of the taxpayer, the reporting period, and information regarding the application of Estonian CIT,
  • Account tags (JPK tags) – a complete list of all ledger accounts, along with relevant classification codes,
  • Accounting entries – presented as a comprehensive journal of economic transactions,
  • Trial balance – a summary of account balances and movements,
  • Contractor data – a list of entities cooperating with the taxpayer,
  • Invoice numbers issued via KSeF – this element will become mandatory following the implementation of structured invoices in Poland,
  • Indication of tax and non-tax accounts.

 

JPK_ST_KR – the Fixed Assets Register

The JPK_ST_KR schema is a newly introduced structure for reporting fixed assets and intangible assets. Its main components include:

  • Identification data – as with JPK_KR_PD, this includes taxpayer details and the reporting period,
  • Fixed assets register – a detailed record of all fixed assets,
  • Classification codes – a list of designations in line with the fixed asset classification system,
  • Depreciation table – comprehensive data on depreciation charges,
  • Register of fixed asset transactions – covering acquisitions, disposals, and asset retirements.

 

JPK CIT Tags: A key component of the new reporting system

The JPK tags are defined and governed by the Regulation of 16 August 2024 concerning additional data to be included in accounting records in accordance with the Corporate Income Tax Act (Journal of Laws 2024, item 1314). 

This regulation introduces a requirement to use tags that identify ledger accounts and facilitate their classification and analysis. These codes enable the tax administration to map taxpayers’ chart of accounts. The tagging dictionary used for this purpose is divided into seven categories:

  • banks,
  • insurance companies,
  • public benefit organisations,
  • investment funds,
  • brokerage houses,
  • credit unions,
  • other entities.

The majority of taxpayers conducting business in Poland will use the JPK tags listed under the final category (“Other entities”), as specified in Annex 7 of the aforementioned regulation.

Importantly, taxpayers preparing financial statements in accordance with International Financial Reporting Standards (IFRS) are temporarily exempt from the obligation to complete tags during the first year of JPK CIT reporting.

 

Preparing for JPK CIT Reporting – audits, risk assessment and IT adaptation

Effective implementation of JPK CIT within a company requires a comprehensive approach. If you are responsible for corporate finance, be sure to follow these five essential steps.

Conduct a thorough analysis of the ERP software used by the accounting department. JPK CIT is an XML file with a defined structure, which can only be generated by a suitably configured accounting system. Verifying whether your company’s system can support the new data structures and tagging requirements is absolutely critical.

Evaluate the quality of the accounting data collected by the company and its compliance with the new requirements. Alternatively, commission a tax audit to identify potential information gaps that could affect the accuracy of JPK CIT reporting.

Review and revise internal accounting procedures—or seek support from experts providing accounting supervision services—to ensure alignment with the new reporting obligations. Introduce clear procedures and prepare guidance for staff on assigning tags to ledger accounts.

Prepare your accounting team for the new responsibilities. Deliver comprehensive training on the updated reporting structures and procedures.

Finally, before submitting your first official report, carry out tests to generate JPK CIT files and ensure that the data is complete and accurate.

The future of tax reporting

JPK CIT represents a fundamental shift in Poland’s approach to tax reporting, clearly signalling a move towards a more digitalised and automated system of tax administration.

There is no doubt that businesses taking strategic preparatory steps today will gain a competitive advantage. Investing in the right systems and processes will not only ensure compliance with the new requirements, but also position the organisation to adapt to future regulatory changes and fully harness the potential of modern tax reporting.

Frequently Asked Questions about JPK CIT

No – JPK CIT is an XML file with a defined structure and can only be generated by a suitably configured accounting system.

Yes – with the exception of entities preparing financial statements under IFRS, which are granted a temporary exemption from this requirement during the first year of JPK CIT reporting.

Yes – the requirement to prepare the Standard Audit File for Tax (JPK CIT) applies to all corporate income tax (CIT) taxpayers, regardless of the size of the enterprise.