Recently, a third draft regulation by the Finance Minister, dated March 22, 2024, concerning additional data for accounting books under the Corporate Income Tax Act, was published by the Government Legislation Center. The Ministry of Finance also introduced new logical structures, JPK_KR_PD and JPK_ST, collectively known as JPK_CIT.
Under these new regulations, taxpayers will now need to submit data based on these two separate logical structures, marking a significant change from the original structure presented in November of the previous year. This will pose various challenges for taxpayers, including adjustments to data collection methods, updates to financial systems, or the implementation of new IT solutions to meet legal requirements.
For the JPK_KR_PD structure, starting from the first tax year beginning after December 31, 2024, and before January 1, 2026, taxpayers will be required to include tags identifying ledger accounts according to accounting ledger account tags. This entails marking income statement accounts for tax purposes, such as categorizing expenses as tax-deductible or non-deductible, and income as taxable or non-taxable. However, this obligation does not apply to taxpayers following IAS and IFRS standards for financial statements.
Regarding the JPK_ST structure, additional information has been included, such as the type of document confirming the acquisition or creation of fixed assets or intangible assets, invoice identification numbers, and contractor identification numbers for purchasing assets.
Initially, the largest CIT taxpayers and tax capital groups are required to submit these logical structures by the CIT return filing deadline for the tax year beginning after December 31, 2024. Subsequently, the obligation will extend to other taxpayers required to submit JPK_VAT records, and then to other CIT taxpayers.
