JPK_CIT is a requirement to submit accounting records data to the tax authority in a standardised XML format, with every entry tagged with tax markers. For companies with revenues above EUR 50m — mandatory from 2025. For all others — from 2026. The key preparation is not just IT — it is updating accounting policy, chart of accounts and cost-coding procedures. Inconsistency between JPK_CIT and the CIT-8 return is tax audit risk number one.
Timeline and scope
| Reporting year | Who submits | First filing deadline |
|---|---|---|
| 2025 | CIT taxpayers with revenues >EUR 50m + corporate income tax groups | Together with CIT-8 for 2025 (typically by 31 March 2026) |
| 2026 | All CIT taxpayers obligated to submit JPK_V7 | Together with CIT-8 for 2026 |
| 2027 | All remaining CIT taxpayers | Together with CIT-8 for 2027 |
JPK_CIT risks — what the tax authority receives
| What the tax authority receives in JPK_CIT | Risk for the taxpayer |
|---|---|
| Trial balance of all accounts (JPK_KR_PD) | Discrepancy between account balance and value in CIT-8 |
| Entries with markers: deductible/non-deductible, limited, tax-exempt | Wrong marker = tax authority challenges the tax classification |
| Fixed asset and intangible asset register (JPK_ST_KR) | Unreconciled difference between accounting and tax depreciation |
| Transaction data broken down by counterparty | Automatic cross-check against counterparties' KSeF files |
What JPK_CIT reports — two structures
JPK_KR_PD — trial balance of accounts with tax markers for each entry: whether a cost is a tax-deductible expense (KUP) or not (NKUP), whether it is subject to limitation (e.g. debt financing costs), whether the transaction is CIT-exempt.
JPK_ST_KR — fixed asset and intangible asset register: accounting value, accounting and tax depreciation, depreciation method, KSeF invoice number of acquisition (where applicable).
5 accounting policy and chart-of-accounts changes
Change 1 — Tax markers (deductible/non-deductible) on cost accounts
Every cost account must have a default tax marker assigned, or a procedure for assigning one at each entry. The chart of accounts must be extended or the accounting system must support an additional "tax classification" field on each entry.
Change 2 — Separation of accounting and tax depreciation
If the company applies different accounting and tax depreciation rates (and most do), JPK_ST_KR requires reporting both values per asset. This requires updating the fixed asset register with tax-specific fields.
Change 3 — Procedure for limited-deductibility costs
Debt financing costs (interest), intragroup intangible service costs, representation costs — must be tagged as subject to limitation. This requires a verification procedure at each invoice.
Change 4 — Consistency with the CIT-8 return
The sum of deductible cost markers in JPK_KR_PD must be consistent with the deductible costs in the CIT-8 return. Discrepancies are a signal for the tax authority to audit. This requires a reconciliation process before filing the return.
Change 5 — KSeF number in the fixed asset register
JPK_ST_KR requires the KSeF invoice number for the acquisition of a fixed asset (from 1 February / 1 April 2026). The fixed asset register must include a KSeF number field and a procedure for capturing it when an asset is added.
Frequently asked questions
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