JPK_CIT reporting: A new dimension of corporate income tax audits in Poland

What information will the tax authorities receive?

JPK_CIT consists of two reporting structures: 

• JPK_KR_PD or Jednolity Plik Kontrolny – Księgi Rachunkowe Podatnika (in English, Standard Audit File for Accounting Books and Income Tax Settlements), covering accounting records; and 

• JPK_ST_KR or Jednolity Plik Kontrolny (in English, Standard Audit File for Tax) containing information on fixed assets and intangible assets.

In practice, Polish tax authorities will gain access to detailed accounting entries, account balances and turnover, contractor information, accounting documents, and differences between accounting and taxable profits. This will enable the authorities to analyse individual business transactions, identify non-deductible expenses, verify depreciation calculations, and compare accounting records with corporate income tax returns.

Importantly, combining information from JPK_CIT, JPK_VAT, and the national e-invoicing system (KSeF) will significantly increase the tax authorities' ability to automatically detect inconsistencies and identify taxpayers for potential audits.

Who Is subject to the new reporting obligation?

The implementation of JPK_CIT has been divided into stages:

• From 2025: Required participation by tax capital groups and corporate income tax payers with revenues exceeding EUR 50 million.

• From 2026: Other corporate income tax payers are required to submit monthly JPK_V7M reports.

• From 2027: Required participation by remaining corporate income tax payers, subject to statutory exclusions.

Reporting takes place after the end of the tax year rather than on a monthly basis. The deadlines for submitting the files are subject to legislative changes.

Consequences for businesses

Previously, many irregularities in the tax classification of expenses could only be identified during an examination of accounting documentation. JPK_CIT will allow the tax authorities to analyse this information without first requesting access to the company's complete accounting records. For businesses, this means ensuring consistency between their accounting records, corporate income tax calculations, and other tax reporting data.

Conclusion

JPK_CIT is changing the nature of tax supervision – moving from audits primarily based on tax returns towards systematic analysis of detailed accounting data.

Companies should therefore approach JPK_CIT implementation not only as an IT project but also as an opportunity to review the accuracy of their tax settlements and the quality of their accounting records.

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Anita Tulak is a graduate of the Faculty of Law and Administration and a tax advisor at the National Chamber of Tax Advisors. She has passed through all levels of career in accounting and tax law, from assistant to partner of a law firm and worked for recognised private consulting firms and the “Big Four” company PwC.