CIT SAF-T in Poland – new reporting obligations to be introduced in 2025 How to get prepared?

Starting from 2025, legal persons in Poland will need to face changes in the reporting of Standard Audit Files for Tax (SAF-T). The Polish Ministry of Finance is introducing new reporting structures as part of the CIT SAF-T (in Polish: JPK_CIT) which will apply to taxpayers of the corporate income tax (CIT).

SAF-T i.e., Standard Audit File for Tax, is a set of data generated from the taxpayers’ ICT systems and it contains information on economic transactions for a particular period, in the XML format, allowing tax authorities to process data.

The current on-demand structure of JPK_KR, including records from accounting books, will become obligatory and expanded with additional information, receiving a new name: JPK_KR_PD. Moreover, a completely new structure of JPK_ST_KR will be introduced to disclose detailed records from accounting books with regard to fixed assets and intangible assets. Both reports will be delivered directly to tax authorities as an xml file.

Introduction of JPK CIT

It is expected that the implementation of new regulations will be gradual, depending on the size and category of taxpayers. In the case of fiscal years starting:

• After 31.12.2024 – the obligation will cover CIT payers in the case of which the value of revenue in the previous fiscal year exceeded EUR 50 million or entities being members of tax capital groups.
• After 31.12.2025 – the new obligations will apply to all CIT payers obligated to send JPK_V7 files.
• After 31.12.2026 – the new regulations will apply to all the other payers of corporate income tax.

Taxpayers whose fiscal year is the same as the calendar year will be required to submit the JPK_KR_PD file along with the CIT-8 tax return for 2025 i.e., by 31 March 2026.

Finalization of the regulation and key changes

On 16 August 2024, the Polish Ministry of Finance officially signed the regulation on CIT SAF-T, confirming that it will become applicable on 1 January 2025. The regulation introduces several crucial modifications:

• Obligation to report the register of tangible assets (JPK_ST_KR) introduced in 2025

Contrary to previous drafts, according to the current version of the regulation, the register of tangible and intangible assets will have to be reported already in the first year in which the new rules become applicable.

• Diversification of the scope of reporting

The regulation introduces the concept of both mandatory and voluntary reporting. It means that some data will have to be reported immediately while other will be optional, allowing the taxpayers to gradually adjust to the new requirements.

The scope of information covered by CIT SAF-T

The regulation imposes the obligation to add new data required as part of JPK_CIT in the managed books. Based on the draft of the regulation, taxpayers must prepare their ledgers to be supplemented with:

• Identification data of the taxpayer’s contractors.
• The invoice identification number in the E-Invoice National System (KSeF) in case of invoices that serve as accounting documents.
• Bookkeeping account identification tags according to the tag glossary provided in the regulation.
• Data on tangible and intangible assets, including the invoice identification number in KSeF and information on the acquisition, creation or removal from records.
• Data concerning differences between the balance sheet result and the tax result, with particular presentation of balance sheet and tax costs and revenues.
• Information regarding taxable income, especially for taxpayers subject to lump-sum on corporate income.

How to prepare for the introduction of CIT SAF-T in Poland?

Taxpayers should begin preparations for the introduction of new CIT SAF-T structures in Poland as quickly as possible:

1. Analysis of the current state and identification of gaps in the systems.
2. Mapping of JPK_KR_PD and JPK_ST_KR structures and planning the changes.
3. Adjustment of IT systems to the new requirements.
4. Conducting system tests.
5. Preparation of procedures for the new reporting model.

Advantages of the introduction of JPK_CIT

The Polish Ministry of Finance indicates numerous advantages resulting from the introduction of the CIT SAF-T:

• For tax offices: better selection of entrepreneurs for inspections, which will allow for more effective combating of tax abuse and elimination of unfair competition.
• For taxpayers: a simplified submission process for CIT declarations, faster communication with fiscal authorities and a reduced risk of errors in tax settlements.

The signing of the regulation on the CIT SAF-T means that taxpayers have little time left to adjust to the new requirements. The adjustment process shall require a thorough transformation of the accounting and IT systems as well as implementing new procedures in order to fulfil the reporting duties that will apply from January 2025.

Author: Małgorzata Sępioł CIT Expert at the MDDP Outsourcing Office in Katowice