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Comprehensive support covering all key stages of implementing the Standard Audit File for CIT
Polish regulations impose on taxpayers the obligation to keep accounting books using computer software and to submit them to the tax office in the form of a Standard Audit File for CIT (JPK_CIT). It must be remembered, however, that aligning bookkeeping processes with this requirement is not simple, and it involves numerous organisational and technological challenges. Therefore, it is worth consulting professional tax advisors specialising in corporate income tax to make sure your company fully complies with the JPK_CIT reporting obligation.
Failure to properly prepare for the obligation to submit JPK_CIT may result in reporting errors, tax penalties, or increased frequency of tax audits.
Since the submission of incorrect files is not possible (the tax authority's system automatically validates the correctness of the JPK_CIT file), any irregularities in this area may increase the risk of fiscal-penal liability for the management. Given the extent of the obligations (and potential consequences), early preparation is recommended, as implementation may take many months.
JPK_CIT is a structured data format consisting of two mandatory structures:
- JPK_KR_PD – a structure containing accounting data related to corporate income tax,
- JPK_ST_KR – a structure containing fixed assets and intangible assets.
The file must be submitted using electronic communication and in a specified logical structure.
Taxpayers must submit the JPK_CIT file to the head of the relevant tax office by the deadline for filing the CIT-8 return. This gives the tax authorities regular insight into taxpayer settlements and more efficient selection for tax audits. To comply with their JPK_CIT reporting obligations, CIT payers must pay greater attention to their filings, as tax authorities may use the data contained in the Standard Audit File for Tax to check and control companies more unexpectedly, without contacting them beforehand in order to obtain specific information.
The provisions of the Regulation of the Minister of Finance of 16 August 2024 on additional data to be included in accounting records maintained in Poland came into force on 1 January 2025.
In accordance with the new regulations, CIT payers are obliged to keep accounting books using computer software and to submit them to the tax office electronically in the form of a Standard Audit File for CIT (JPK_CIT). A key change is the requirement to report in XML format.
Taxpayers will be required to submit JPK_CIT for the first time for the tax year beginning after:
- 31 December 2024 – in case of:
- tax capital groups,
- taxpayers whose revenue in the previous tax year exceeded the equivalent of EUR 50 million;
- 31 December 2025 – in case of taxpayers already obliged to submit JPK_VAT records.
Note! If the taxpayer’s fiscal year coincides with the calendar year, the first JPK_CIT must be submitted by 31 March 2026 (for large taxpayers) or by 31 March 2027 (for remaining CIT payers that follow such an accounting period), and it must include entries for the period beginning from 1 January 2025 or 2026 respectively.
The JPK_CIT structure among other things includes:
- account identifiers (according to the Ministry of Finance dictionary),
- data on differences between accounting and tax results,
- journals, all accounting records, and trial balances,
- detailed records of fixed and intangible assets,
- and eventually – invoice numbers from the National e-Invoicing System (KSeF) used as accounting evidence.
Steps to be taken to implement the Standard Audit File for Corporate Income Tax
Preparing the company for submitting JPK_CIT files involves reorganisation of internal processes and adaptation of existing technological solutions. CIT taxpayers must first and foremost modify their financial and accounting systems to fully comply with the new technical and legal requirements. The most important actions to take are:
- comprehensive review of accounting structures,
- mapping accounts to Ministry of Finance dictionaries, integrating data from various sources, and often updating or replacing existing ERP accounting systems.
- adjusting the chart of accounts,
- modifying posting schemes,
- adding required tags to account descriptions,
- implementing new internal reporting procedures.
A crucial element of JPK_CIT implementation is staff training – to ensure effective operation under the new structures.
How can RSM Poland's tax advisors help you to introduce JPK_CIT reporting obligation in your company?
RSM Poland offers comprehensive support covering all key stages of JPK_CIT implementation. Our focus is on compliance, process optimization, and minimizing the risk of errors and sanctions.
- Data and transaction analysis – we review financial and tax data, identify discrepancies between accounting and tax results, and support the CIT calculation process.
- Account and tax tag mapping – we verify recording principles and help assign tags according to the Ministry of Finance requirements.
- Review of accounting and fixed asset ledgers – we ensure completeness and accuracy of general ledgers as well as records of fixed assets and intangible assets.
- System assessment and technical preparation – we assess the readiness of IT systems to generate JPK_CIT files and support necessary technical adjustments.
- Data testing and validation – we assist in testing JPK file accuracy, reconciling data with CIT returns, and building internal control mechanisms.
- We provide training for finance and tax department staff, preparing them for the new reporting obligations.
Furthermore, we offer a comprehensive service of preparing JPK_CIT files in an outsourcing model – without the need to implement complicated solutions on your end. This solution is ideal for companies that do not have the technological resources or a team ready to prepare the JPK structure on their own.
Our professional tax advisory & consulting services provided by leading experts guarantee peace of mind during a tax audit and ensure the efficiency of financial processes in your company. If you are looking for a trusted partner who will assist you in the preparations for JPK_CIT reporting, feel free to contact our specialist, who will be happy to answer all your questions and will tailor our offer to your individual needs.
