Major Changes in Tax Reporting Are Coming

Exceeding the revenue threshold of EUR 50 million in 2024 means not only joining the ranks of the largest companies but also facing new reporting obligations. Starting in 2025, the obligation to report JPK CIT (Polish Standard Audit File for Corporate Income Tax) has come into effect, representing a key element of Poland's digital tax transformation. For international groups, this is a significant technical and organizational challenge, as they need to adapt global financial and accounting systems—often standardized group-wide—to the specific requirements of Polish JPK CIT reporting. This requires not only software modifications but also restructuring of accounting processes, staff training, and ensuring data integrity between central systems and local solutions that comply with Polish tax regulations.

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Key Distinctions for Foreign Entities - Forms of Business Activity

It is worth emphasizing that JPK CIT obligations will not be limited to the largest companies. As of 2026, it will extend to entities that report JPK VAT, and by 2027, it will include all CIT taxpayers. Consequently, foreign businesses active in Poland should begin their preparations now to avert future complications.

It's no surprise that the first individual tax rulings issued by tax authorities began appearing in the fourth quarter of 2024. Their analysis shows that the key aspect of JPK CIT reporting is the form of business activity in Poland - especially for foreign entities. These are the areas where taxpayers have the most questions, and tax authorities are gradually establishing interpretative guidelines.

One of the key aspects that the Ministry of Finance has not yet specified is the scope of reporting obligations for various forms of foreign entities' activities in Poland.

Branch Office in Poland = JPK CIT? Key Rules for Foreign Entities

Foreign companies operating in Poland through branches or representative offices must comply with local accounting regulations - which also means the obligation to report JPK CIT. However, the key point is that for branches, only revenues generated in Poland are considered, not the global results of the entire company.

This is a significant issue for international enterprises whose Polish branches often constitute only a small part of their operations. An individual tax ruling (ref. no. 0111-KDIB3-2.4018.19.2024.2.SR) confirms that when calculating the mandatory reporting threshold, only local revenues are counted.

Permanent Establishment Without JPK CIT - When Is There No Reporting Obligation?

The legal situation is different for entities that have only a permanent establishment in Poland, without a registered branch or representative office. These entities are not subject to the obligation to maintain accounting books according to the Polish Accounting Act. Consequently, they will not be subject to JPK CIT reporting requirements, regardless of their revenue level. In their case, maintaining simplified tax records for corporate income tax purposes is sufficient.

This position was explicitly confirmed in an individual tax ruling (ref. no. 0114-KDIP2-2.4010.562.2024.3.AP). The tax authority clearly indicated that the lack of obligation to maintain accounting books means that there can be no obligation to maintain them electronically and submit them as JPK CIT.

Practical Aspects of JPK CIT Implementation

For entities required to report JPK CIT, implementing the new requirements involves numerous technical and organizational challenges. Adapting IT systems is of crucial importance. It will be necessary to verify whether currently used accounting software enables generating files in the required format. In many cases, modification or even replacement of systems may be necessary.

Equally important are organizational changes. Implementing new reporting requirements often necessitates reviewing and modifying accounting processes and training staff. It is also essential to develop appropriate data quality control procedures to ensure the accuracy of transmitted information.

Large Systems, Big Challenges

For large organizations using advanced ERP systems such as SAP, Oracle, Dynamics 365, implementing JPK CIT may prove an even greater challenge. Many international companies use unified financial and accounting systems at the group level, which are globally adapted to corporate standards. Introducing Polish requirements may therefore require significant modifications - not only in terms of reporting structure but also system architecture itself.

One of the key issues may be adapting the chart of accounts to Polish regulations. In corporate systems, accounting accounts are often standardized across the entire group and may not correspond to Polish requirements for JPK CIT reporting.

Another issue is the need to mark data with appropriate tags required in the JPK CIT structure. ERP systems rarely have native mechanisms adapted to specific Polish regulations, which means implementing new functionalities or integrating with external reporting modules is necessary. Companies may face a dilemma: adapt the global system or implement additional local tools for JPK CIT reporting?

How to Prepare?

Given the upcoming changes, it's worth taking concrete steps now to efficiently implement JPK CIT requirements and avoid potential problems. Understanding whether an entity will be subject to reporting obligations is crucial, but so is preparing systems, processes, and teams for the new regulations.

✔ Organization Status Analysis – The first step is to precisely determine the form of business activity in Poland. It's worth verifying whether the company operates through a branch, representative office, or has only a permanent establishment, as this determines the reporting obligation. Based on this, you can also determine when the company will be required to submit JPK CIT.

✔ IT and Financial Systems Audit – It's worth conducting a detailed analysis of accounting and ERP systems regarding their readiness to generate JPK CIT. Check whether the systems enable correct data export according to the Polish reporting structure and whether they will require adaptation, e.g., in terms of chart of accounts, transaction marking, or file formatting.

✔ Verification of Books with Accounting, Tax, and JPK CIT Requirements – It's crucial to analyze whether the company's method of maintaining accounting books complies with Polish regulations and JPK CIT reporting requirements. This applies to compliance with both the Accounting Act and tax regulations, as well as detailed requirements of the JPK CIT structure.

✔ Action Plan and Implementation Schedule – Based on the analyses conducted, develop a detailed JPK CIT implementation plan, considering both technical and organizational aspects. Appropriate scheduling of work is crucial so that changes can be implemented without disrupting the company's ongoing operations.

Due to the gradual expansion of the JPK CIT obligation, companies should act now to avoid problems in coming years. Early preparation will allow not only for smooth system adaptation but also for limiting tax risk and avoiding potential sanctions related to incorrect reporting.

Let Us Help You

CRIDO's expert team combines specialists from business, technology, and tax-legal areas, experienced in JPK CIT implementation. We offer comprehensive support including conducting detailed analysis of reporting obligations in the context of your specific business activities, consulting on adapting financial and accounting systems, and support in preparing and verifying JPK CIT reports.

Contact us to discuss how we can support you in this process.