JPK CIT and JPK_ST_KR in Poland: the scope of the temporary exemption and preparing data

JPK CIT combines several connected obligations. News of a fixed-asset exemption should therefore not stop the whole implementation. Poland’s Ministry of Finance has announced the signing of a regulation covering computerised maintenance of those records and transmission of JPK_ST_KR. The general ledger, tax classification of entries and preparation of JPK_KR_PD require separate assessment.

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JPK_KR_PD and JPK_ST_KR serve different purposes

Article 9(1c) of the Polish CIT Act provides the basis for electronic CIT books: keeping the relevant records using software and transmitting them electronically. Additional data and the transmission structure must be read together with implementing rules. Poland’s National Revenue Administration (KAS) also identifies Article 9(1e) and (1g) of the CIT Act and Article 193a §2 of the Tax Ordinance as relevant legal bases.

JPK_KR_PD concerns accounting books for income-tax purposes. JPK_ST_KR concerns fixed assets and intangible assets of entities keeping accounting books. The asset file does not replace the ledger file. JPK_V7, in turn, serves VAT reporting. Being able to submit JPK_V7 correctly does not establish that the books are ready for CIT reporting.

Implementation has three layers: maintaining data in the system, adding the required tax information, and generating and transmitting the file. An exemption may cover a particular layer and dataset. Read its scope instead of extending it to every obligation called “JPK CIT”.

What the announcement says about the temporary exemption

According to the Ministry, the measure covers fixed-asset and intangible-asset records of CIT taxpayers and specified partnerships without legal personality. It covers both keeping those records using software and transmitting the data in JPK_ST_KR. It is intended for tax years, or the relevant partnerships’ financial years, beginning after 31 December 2025 and before 1 January 2029.

The decisive date is the start of the year, not merely the transmission date. For calendar-year entities, the stated interval would cover 2026–2028. A non-calendar year requires mapping the actual dates. It does not follow that every submission made in 2029 is either covered or excluded.

The measure does not remove the need to establish initial asset value, document the asset’s entry into use or calculate depreciation correctly. Substantive duties follow, among other provisions, from Articles 16a–16m of the CIT Act; Article 9(1) governs records. Exemption from a particular electronic duty does not permit arbitrary tax deductions.

When the remaining JPK CIT duties apply

KAS describes a phased rollout. The first stage, for years beginning in 2025, covers tax capital groups and entities above the relevant EUR 50 million revenue threshold. Specified entities submitting JPK_V7M join from 2026. Remaining entities, including those using JPK_V7K, follow from 2027. Classification requires checking taxpayer status and transitional provisions.

Distinguish the year of maintaining data from the deadline for transmitting it. Where implementation concerns 2026 books, data must be prepared during that year even though annual submission happens later. Do not calculate a specific deadline without checking current rules and any postponement for the relevant group.

Checking the data before the final file is generated

Start with data sources and responsibility, rather than the export button. Accounting understands the entries and documents; the tax team assesses CIT treatment; the software provider maps the technical structure. None of those roles replaces the others.

For example, accounting depreciation may total PLN 180,000, while deductible tax depreciation is PLN 142,000. The PLN 38,000 difference needs a documented explanation, such as a statutory cap or a different rate. A technically valid file cannot determine that for the taxpayer. This test remains possible even when transmission of the asset register itself is temporarily exempt.

Using the time provided by the exemption

The Ministry’s announcement describes the exemption’s scope without a detailed diagnosis of implementation difficulties. We therefore do not attribute unstated motives to the legislator. A practical consequence may be the ability to stage work on assets and the general ledger. That is our organisational assessment, not an additional legal rule.

Keep a written cohort assessment, the date and legal basis for applying the exemption, and a list of duties that remain. Test a representative month and year-end, reconcile discrepancies and identify who approves the result. Acceptance of system changes is particularly important: installing an update does not constitute tax approval of the data.

JPK CIT after a merger or with a non-calendar tax year: what must be reported?

The additional-data rules derive from the Finance Minister’s Regulation of 16 August 2024, Dz.U. item 1314. Section 2(1)(3) concerns account markers and point 5 concerns differences between accounting profit and the tax base. Implementation rulings show why the obligation, data scope and transitional period require separate analysis. The following cases concern their specified years; they do not themselves extend exemptions to later years.

JPK CIT after a merger: how can data from two accounting systems be reported?

In the ruling of 20 February 2025, 0111-KDIB1-3.4010.756.2024.1.ZK, an acquiring company could not technically produce one combined annual file. KIS accepted the described split: one set covered the acquirer before the merger and both companies afterwards; another covered the acquired company before the merger.

The solution followed the merger timeline: separate books before the merger and combined operations afterwards. Completeness across the year mattered. Map each period to its books and reporting file, then reconcile the boundaries where transactions could otherwise disappear or be reported twice.

Completeness, reliability, continuity and conformity with the structure mattered. Prepare a “company — period — system — file” matrix to prevent omissions and duplication. This is not general permission to split JPK arbitrarily: the accepted model concerned specific succession and data arrangements. Structures mentioned in the ruling also require assessment against exemptions applicable to the particular year.

JPK CIT with an October tax-year start: which year’s revenue determines the threshold?

The ruling of 11 April 2025, 0111-KDIB1-1.4010.23.2025.1.MF, rejected the applicant’s position. The company examined revenue for 1 October 2023–30 September 2024. For the first tax year starting after 31 December 2024, namely 1 October 2025–30 September 2026, the authority identified the relevant preceding year as 1 October 2024–30 September 2025.

The test used the year immediately preceding the first year considered under the rule. With a non-calendar year, choosing the most recently completed accounts intuitively can select the wrong period. Put the tax-year opening, revenue reference year and filing deadline on the same timeline.

If revenue for that correct period did not exceed EUR 50 million, the first reported year under the case assumptions was 1 October 2026–30 September 2027. The authority nevertheless rejected reasoning based on the earlier revenue period. An apparently expected outcome therefore does not establish correct qualification. Current implementation also requires checking the applicable JPK_V7M/JPK_V7K rules; the ruling assessed the law at its own date.

PD markers in the 2025 JPK_KR_PD: what did transitional relief cover?

In the ruling of 5 September 2025, 0111-KDIB2-1.4010.300.2025.2.BJ, a company wanted Section 5(1) relief to cover markers PD1–PD8_PB_2. KIS rejected this: the transitional rule listed Section 2(1)(1), (2), (4) and (5), omitting point 3 on markers.

The decisive point was the provision’s references to specific numbered data requirements. It omitted the marker requirement, so the general aim of easing initial reporting did not extend the exemption. Map each data category to its legal basis rather than treating relief as a single switch for the entire file.

The company did not apply IFRS and thus failed the separate condition in the then Section 5(2). Break “additional-data relief” down into individual fields. Partial relief does not authorise an empty marker section. This assessment concerned the 2025 books, rather than an indefinite exemption or obligation for every entity.

JPK CIT in a tax capital group using IFRS: do all companies report alike?

In the ruling of 9 May 2025, 0114-KDIP2-2.4010.138.2025.2.PK, KIS accepted the temporary 2025 marker exclusion for a tax-capital-group member preparing IFRS financial statements. Article 9(1g) CIT and Section 5(2) mattered: individual companies keep books, and the tax group does not replace their accounting separateness.

The tax capital group is the CIT taxpayer, but its companies maintain separate accounts. The particular entity’s reporting standard mattered for marker relief. A group implementation therefore needs a company-by-company map of accounting standards and reporting requirements, even though the tax result is settled jointly.

Group membership does not make every system’s data requirements identical. Determine each company’s accounting standard and grounds for applying the rule. The ruling concerned its stated transitional period and does not justify automatically omitting markers afterwards. Another taxpayer’s individual ruling does not automatically protect your business.

Estonian CIT does not remove JPK: a final judgment

In the judgment of 15 May 2025, I SA/Wr 875/24, the Wrocław administrative court dismissed a company’s challenge concerning Estonian CIT. CBOSA marks the judgment as final. The company argued that it did not recognise revenue under ordinary CIT rules, so high accounting revenue should not trigger the first JPK phase.

The court disagreed. Article 9(1c) also refers to the Article 28r(1) return, and Estonian-CIT taxpayers are not generally excluded. Revenue established from the company’s books mattered in this case. Deferral of tax on retained profit therefore does not defer book-reporting obligations. The judgment concerns phase qualification; it neither abolishes nor expands the later JPK_ST_KR relief.

Reconciling accounting profit with CIT: numerical example

Our own model, without figures from the cited cases. A company under ordinary CIT has PLN 1,000,000 accounting profit before tax. Its accounting expenses include PLN 30,000 of representation expenses assumed non-deductible under Article 16(1)(28). Accounting depreciation is PLN 100,000 and correctly determined tax depreciation PLN 115,000. Assume no other adjustments, losses or reliefs, and applicability of the 19% rate.

A technically valid export showing only PLN 1,000,000 does not prove that CIT is correct. Each adjustment needs supporting entries and documents and correct representation in the structure. Account mapping and markers must reflect the entries’ substance and the relevant dictionary under Section 2(3). Assigning one label to every expense, or treating permanent and temporary differences identically, is insufficient.

TLP can review the applicable duties and a trial file, reconciling the source data with your Polish CIT position.

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• Does the JPK_ST_KR exemption allow all JPK CIT work to stop?
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