JPK_CIT – important changes in the decree issued by the Minister of Finance

The ordinance submitted for publication differs from previously published drafts - JPK_CIT has been expanded to include additional data.

According to the final version of the regulation, accounting books must be supplemented by:

1. Tax identification number of the taxpayer's contractor, if assigned.
2. The invoice identification number in the National e-Invoice System, if assigned by the date the ledger is submitted—in case of invoices issued by the taxpayer as accounting evidence.
3. Identification tags for ledger accounts as reported according to the ledger account identifier dictionary.
4. Data confirming the acquisition, creation, or removal of a given fixed or intangible asset from the register of fixed and intangible assets:
   • In case of invoices serving as accounting evidence for the disposal of a fixed or intangible asset—the invoice identification number in the National e-Invoice System, if assigned by the date the ledger is submitted.
   • The number of the accounting document based on which acceptance is granted for using the fixed or intangible asset.
   • The type of accounting document verifying the acquisition, creation, or removal from the register.
   • The date of acquisition, creation, acceptance for use, or removal from the register.
   • The inventory number assigned by the entity.
5. The difference amount between the financial result determined based on accounting regulations and the tax base determined based on corporate income tax regulations, broken down into:
   • The amount of revenue exempt from taxation—permanent differences between the accounting profit (loss) and the taxable income (loss) are reported.
   • The amount of revenue not subject to taxation in the current year.
   • The amount of revenue subject to taxation in the current year, recorded in the books from previous years.
   • The amount of taxable revenue not recorded in the books.
   • The amount of expenses not recognized as tax-deductible costs—permanent differences between the accounting profit (loss) and the taxable income (loss) are reported.
   • The amount of expenses not recognized as tax-deductible costs in the current year.
   • The amount of expenses recognized as tax-deductible costs in the current year, recorded in the books from previous years.
   • The amount of expenses recognized as tax-deductible costs, not recorded in the accounting books.

Important!

The draft regulation of 22.03.2024 did not provide for points d and e in paragraph 4.

The wording of point d has been changed and point h of paragraph 5 has been added. Data included in the JPK_CIT relative to the version from the first half of the year has been expanded by:

• The date of acquisition, creation, acceptance for use or deletion from the register, and the inventory number assigned by the entity for data confirming the acquisition, creation or deletion of a given fixed or intangible asset from the register of fixed and intangible assets.
• The amount of taxable revenues not subject to recognition in the books; the amount of expenses recognized as tax deductible costs, also not subject to recognition in the books, as new distributions of the difference amount between the financial result determined based on accounting regulations and the tax base determined based on corporate income tax regulations.

Cases in which ledgers may not be supplemented with additional data

Regulations provide certain exceptions that make the first year of the JPK_CIT regulations—i.e., the upcoming tax year—a "transitional period," during which many of the "target" JPK_CIT requirements will not apply. Specifically, ledgers for the tax year beginning after December 31, 2024, and before January 1, 2026; and in the case of non-corporate entities, for the financial year beginning after December 31, 2024, and before January 1, 2026; may not need to be supplemented with the following information/data:

• Tax identification number of the taxpayer's contractor, if assigned.
• The invoice identification number in the National e-Invoice System, if assigned by the date the ledger is submitted.
• Data confirming the acquisition, creation, or removal of a given fixed or intangible asset from the register of fixed and intangible assets, such as: the invoice identification number in the National e-Invoice System; number of the document based on which acceptance is granted for using the fixed or intangible asset; the type of document confirming the acquisition, creation, or removal from the register; the date of acquisition, creation, acceptance for use, or removal from the register; the inventory number assigned by the entity.
• The difference amount between the financial result determined based on accounting regulations and the tax base determined based on corporate income tax regulations, broken down into: amounts of exempt, non-taxable, and taxable income; amounts of expenses recognized and not recognized as tax-deductible costs.

Additionally, books may not be supplemented with additional data for a given tangible or intangible asset entered in the records prior to January 1^st, 2025. Issuers of securities and entities who are part of a group in which the parent company prepares consolidated financial statements in accordance with International Accounting Standards may not supplement the books for a tax year beginning after December 31, 2024, and before January 1, 2026.

The regulation will go into effect on January 1, 2025.

We will describe the changes for additional entities other than banks, brokerage houses, insurance and reinsurance companies, in a separate article.