New structures for 2025 JPK_KR accounting reporting for transactional-level reporting for company and income tax
The Polish tax authorities have publish new SAF-T CIT logical structures last week. From 1st January 2025, large businesses will be obliged to provide the Polish version of SAF-T – JPK_KR (Jednolity Plik KontrolnyKsięgi Rachunkowe (Accounting books)).
This is in addition to the VAT version, JPK_VAT, which replaced the traditional Polish VAT return in October 2020. With the VAT submissions, and delayed Polish KSeF e-invoicing mandate, the Polish authorities are looking to ensure any transactional-level discrepancies are identified and resolved immediately.
A public consultation was completed in December 2023. This new requirement has already been delayed twice in the past.
Phase launch 2025 to 2027
The imposition of the reporting requirement will be phased in as follows:
- Jan 2025, large companies – sales about €50million per annum;
- Jan 2026, Other businesses subject to corporate income tax and personal income tax payers with accounting records; and
- Jan 2027, all other corporate or personal income taxpayers.
According to the draft regulation, the submitted JPK_KR accounting books should be supplemented with:
- identification data of the taxpayer’s contractor (primarily the tax identification number);
- the invoice identification number in the National e-Invoice System, if assigned, only in the case of invoices constituting accounting evidence;
- tags identifying account accounts shown according to a dictionary of tags (indicated in seven annexes to the regulation) identifying account accounts for:
- banks,
- insurance and reinsurance companies,
- units referred to in Art. 3 section 2 of the Act of April 24, 2003 on public benefit activities and volunteering (Journal of Laws of 2023, item 571), preparing financial statements in accordance with Annex No. 6 of the Act of September 29, 1994 on Accounting (Journal of Laws Laws of 2023, items 120, 295 and 1598),
- investment funds,
- brokerage houses,
- cooperative savings and credit unions,
- other units;
- data confirming the acquisition, production or deletion from the register of a fixed asset or intangible asset:
- in the case of invoices constituting accounting evidence – the invoice identification number in the National e-Invoice System, if assigned,
- specifying the type of evidence confirming purchase, production or deletion from the register,
- tax identification number of the taxpayer’s contractor;
- the amount, type and type of difference between the balance sheet result and the tax result (indication of permanent and temporary differences); The types of differences between the balance sheet result and the tax result are to be determined in the developed JPK_KR logical structures as follows:
- BUY – tax expense that is not a balance sheet expense,
- NKUP – balance sheet expense that is not a tax expense,
- PP – tax revenue that is not balance sheet revenue,
- NPP – balance sheet income that is not taxable income,
- PNPO – non-taxable income,
- KPNPO – costs related to non-taxable income,
- DW – tax-free income;
- the amount and type of taxable income in relation to taxpayers taxed on a lump sum basis on company income.
Since October 2020, Poland became the first country to replace the summary VAT return with monthly / quarterly mandatory SAF-T transaction data submission. In Poland, Standard Audit Files for Tax are known as JPK_V7M/K – Jednolity Plik Kontrolny. The return is generally due by the 25th of the month following the reporting period.
