JPK CIT reporting

The single control file for accounting data and CIT settlements (JPK CIT) is a new obligation for the transmission of accounting data. It is the next stage of digitisation in tax settlements and implies modifications to accounting systems and existing practices. With this solution, the tax authorities will gain access to a large range of accounting and tax data, so it is worth preparing well for it.

JPK_CIT is indicated as the next element of the system that will be used to target entities for audits and increase the effectiveness of authorities in this regard. Through this tool, authorities will gain insight into detailed data regarding CIT settlements, transfer pricing information, and even B2B contracts.

How to submit data for JPK CIT?

JPK CIT reporting comprises two schemas:

JPK_KR_PD – single control file_accounts_income tax – reporting on, among other things, the full journal from the books of account, the trial balance with ministry tags for accounting accounts and data on tax income and expenses. This structure is to be distinguished from the currently applicable JPK_KR schema, which does not have to be obligatorily sent to the authorities.
JPK_ST_KR– single control file_fixed assets_accounts – concerns tax and balance sheet fixed asset records, depreciation details and information on the acquisition, production, disposal or liquidation of a fixed asset.

The transmission of structured data to the tax office will take place once a year, on the deadline for filing the CIT-8 return.

Who will be affected by the JPK CIT?

According to the regulations, the obligation will be implemented according to the following schedule:

From 31 December 2024. – for tax capital groups and CIT taxpayers whose revenue value in the previous tax year exceeded EUR 50 million;
From 31 December 2025. – for other CIT taxpayers who are obliged to send JPK_VAT records;
From 31 December 2026. – for other CIT taxpayers.

What data will be recorded in JPK CIT?

The data to be reported may include information that has not been subject to accounting records so far. Therefore, the new obligation requires adequate preparation in terms of implementing changes to the accounting system or updating the chart of accounts, as well as training of accounting departments.

Additional data that will be subject to recording are:

Taxpayer’s counterparty NIP;
The invoice identification number in the National e-Invoice System;
Official tags identifying individual accounting entries;
Data confirming the acquisition, creation or deletion from the fixed assets register or intangible assets register;
Data on the amount of the difference between the accounting result and the tax result, broken down by category.

Importantly, JPK CIT data will be reported separately for transactions with related and unrelated parties. Based on these data (through internal comparisons), the tax authorities may assess whether prices differ between related-party and unrelated-party transactions. As a result, the information contained in JPK CIT may play a crucial role during transfer pricing audits or verification activities.

Implementation of JPK CIT and R&D Relief

The implementation of JPK CIT involves expenses such as:

purchase/expenses for software customization,
expenses for integrating IT systems,
expenses for testing and implementation work.

Can these expenses be considered as qualifying costs for the R&D relief? Yes, but under certain conditions:

If the implementation of JPK CIT involves development work (e.g., creating or significantly modifying IT systems, innovative solutions), part of the costs may qualify for the R&D relief.
These activities must be creative and innovative in nature, conducted in a systematic and planned manner, and properly documented.
The relief cannot cover work solely related to the implementation of purchased software or its mere deployment, as there is no creative or developmental element involved.

What JPK CIT implementation processes may qualify for the R&D relief?

Analysis of data preparation and processes within the organization to align with the requirements of new obligations and structures.
Mapping of data from the ERP system to the appropriate fields in the JPK_CIT structure.
Audit and update of accounting software.
Architectural changes and integration of accounting systems.
Collection of business requirements for changes in existing systems.
Ensuring data consistency and quality (QA).
Automation of data flows and reporting.
Verification of the correctness of generated JPK files and testing of implemented solutions.
Post-implementation verification/stabilization.

How can we help?

Analysis of the chart of accounts and the current JPK_KR and preliminary tag mapping with indication of recommended modifications;
Analysis and adjustments of the Fixed Asset Register (tax and accounting) and depreciation tables;
Update of policy/practice related to purchases settlement or investments settlement;
Identification of deficiencies in relation to the JPK_ST_KR and recommendations for significant corrections to the data in the records;
Analysis of the current CIT calculation, including the tax note, how the tax result is calculated in comparison with the income statement, together with recommendations;
Support in the preparation of the JPK CIT file, immediately prior to the formal fulfilment of the obligation, based on substantive data from the Company’s accounting system.
Trainings for accounting departments

MDDP will provide you with comprehensive support in the area of JPK CIT. We cooperate with MDDP Outsourcing and IT service providers in the area of tools supporting the settlement from the technological side, thanks to which we offer complete advisory services in the implementation of JPK CIT obligations, e.g. in the verification of chart of accounts, fixed asset register or accounting methods.

Additionally, we will help assess whether the data reported in JPK CIT could raise any concerns in the eyes of the tax authorities from a transfer pricing perspective. In particular, we will consider whether they could be treated by the authorities as “comparable data” (within the meaning of the transfer pricing regulations) and used to increase the Company’s taxable income during a potential audit.