The obligation to send the JPK CIT file was introduced by the Polish Deal. Check which entrepreneurs are affected and when the new obligations for CIT taxpayers come into force.
Schedule for the introduction of JPK CIT
When the obligation to send the JPK CIT file will come into force for individual entrepreneurs depends on 2 factors. The first is revenue, and the second is the status of an active VAT taxpayer. The new obligations for CIT taxpayers will come into force on the following dates:
- data for 2025 for CIT taxpayers exceeding EUR 50 million in revenue in the previous tax year,
- data for 2026 for CIT taxpayers and PIT taxpayers who need to send JPK_VAT files
- data for 2027 for other CIT taxpayers.
Although the new rules will apply from 1 January 2025, for the first time the JPK CIT file will be sent only after the end of the financial year. The deadline for sending this file is combined with the deadline for submitting the CIT-8 declaration. This means that for the first time, the largest CIT taxpayers will have to send data to the Ministry of Finance by 31 March 2026. In the case of the largest CIT taxpayers whose tax year does not coincide with the calendar year, they will have to submit JPK CIT for the tax year starting after 31 December 2024. The situation is similar in the case of CIT taxpayers sending JPK_VAT files who use a financial year other than the calendar year. Such taxpayers will send SAF-T CIT for the first time for the financial year starting after 31 December 2025.
What should the JPK CIT file contain?
The JPK CIT file is based on the structure of the JPK_KR file. However, it has been adapted to the specifics of CIT taxpayers. Therefore, the new obligation is in fact to provide the data contained in the taxpayer’s accounting books. It is true that until now, tax authorities could request an entrepreneur to send their books of account in the form of a JPK_KR file. However, according to the new regulations, this will be mandatory for all CIT taxpayers. In addition to the data that are normally included in the accounting books, new JPK CIT files must contain the following information:
- Contractor’s NIP (Tax Identification Number),
- KSeF identification number,
- Official account tags,
- The amount of the difference between the balance sheet result and the tax result,
- Data confirming the acquisition, production or deletion from the register of fixed assets and intangible assets.
The contractor’s NIP must be reported only if the contractor has such a number. Therefore, this will not apply to sales to natural persons who do not conduct business activity or foreign entities that do not have a registered office or branch in Poland. The identification number of invoices from the National e-Invoicing System will have to be included in the JPK CIT file only when the KSeF becomes mandatory.
Will the obligation to keep the accounting books of CIT taxpayers change?
Although in the case of the largest CIT taxpayers, the first mandatory JPK_CIT files will not be sent until 2026, it is worth preparing for the upcoming changes today. For this purpose, the books to be submitted to the tax authorities must be supplemented with additional data required by the amendment to the CIT Act. It should also be remembered that in the case of CIT taxpayers taxed with a lump-sum tax on corporate income, it is necessary to provide the amount and type of taxable income. For this reason, it is a good idea to enter additional data into the accounting books now. This will certainly facilitate the timely submission of the JPK CIT file.
