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Changes in the JPK CIT Project

JPK CIT will be a new format for electronically submitting accounting data directly to tax authorities, set to become mandatory from January 1, 2025. Many businesses are surprised by the rapid implementation of this control file, particularly because the prior rollout of KSeF was expected. The introduction of JPK CIT represents a significant change for CIT taxpayers, offering benefits but also introducing new challenges. ACS provides services to help you prepare for this requirement and guide you through the process.

On August 5, a new document was published on the Government Legislation Center’s website, which is currently under review by the Legal Commission. The website now offers a package of documents, including the modified draft regulation, the justification for the project, and the Legal Commission’s comments.

The latest version of the draft regulation introduces significant benefits for taxpayers. For the tax year starting after December 31, 2024, and ending before January 1, 2026, the first year of the JPK_ST_KR structure’s implementation, reporting within this structure will be optional.

However, the project does not only introduce benefits. The register of fixed assets and intangible assets now includes a requirement to report the acquisition, production, commissioning, or decommissioning dates, as well as the inventory number assigned by the entity. An interesting aspect of the new regulations is the approach to historical assets. Although there will be no obligation to report fixed assets and intangible assets recorded before January 1, 2025, there are certain exceptions that may lead to interpretation issues. This provision will not apply to fixed assets and intangible assets that were sold with an assigned KSeF number and with regard to the date of their removal from the register.

Special emphasis has been placed on the ambiguities stemming from the wording related to the removal date from the register. This wording suggests a broader scope of data than intended and reveals a discrepancy between the text of the regulation and the intention expressed in the justification. Furthermore, the regulation indicates that it will only apply to fixed assets and intangible assets documented by an invoice during the voluntary KSeF period and removed before that time. When these ambiguities are transferred to the JPK_ST_KR structure, a problem arises in the form of incomplete data entry. Unlike the KSeF number, the removal date from the register is essential for proper validation. To avoid the need to fill in all required data instead of just the removal date and KSeF invoice number, changes in the mandatory fields should be made.

The new project also includes clarifications on the method of data reporting. These clarifications concern, among other things, the assignment of accounting account markers, reporting data on NIP and KSeF numbers, as well as fixed assets and intangible assets.

To prepare for the upcoming changes, it’s advisable to start the implementation as soon as possible. Our specialists will provide you with professional support and ensure a smooth process. Contact us today.