110 JPK_CIT (SAF-T for CIT) projects delivered

The Basic Regulation (Journal of Laws of 2024, Item 1314) introducing mandatory reporting of new JPK structures for Income Tax (JPK_KR_PD) and Fixed Assets (JPK_KR_ST), commonly referred to as “JPK_CIT”, was concise. However, the following two years brought numerous changes: the regulations were supplemented with further clarifications, mandatory submission deadlines were postponed, and the same provisions were sometimes interpreted differently by accountants, tax advisors, and project teams. Therefore, in parallel with the technical preparations, it was necessary to keep track of the publication of subsequent regulations, changes in deadlines, informational brochures, and the Ministry of Finance’s updated and expanding knowledge base (approximately 150 questions and answers).

Some issues were still open to interpretation by the statutory filing deadline, so the projects also required tax and accounting decisions. This highlights the crux of the problem: JPK_CIT was not an obligation that could be fulfilled simply by reading the regulations, mapping the data, and generating an XML file from the information in SAP. In many cases, before configuring the solution, it was first necessary to determine how a specific requirement should be interpreted within the context of a given organization.

While implementing over 110 JPK_CIT projects in SAP, we primarily supported our clients in translating new tax obligations into concrete, actionable solutions that are in line with the latest regulatory knowledge and tailored to their business needs.

The first step was to determine whether the level of detail in the accounting records maintained in SAP was sufficient and, next, how to present the relationships in light of the new requirements.

Updating SAP with the required data related to the JPK_KR_ST structure also proved to be quite a challenge. JPK_CIT quickly made it clear that simply having the information in the system in its current form was not enough for reporting purposes. It was often necessary to review data, update KŚT or inventory numbers, and, above all, supplement the records with parts of the accounting analytics that had previously been maintained outside of SAP, as well as organize how they were stored.

A good example of a data preparation process is the business transaction date. JPK_CIT requires this information for accounting documents, in addition to the document date and the posting date. In SAP S/4HANA , the corresponding field is available by default, whereas in SAP ECC , some customers had to extend the system with an additional field and map it to the JPK_KR_PD report.

In cases where data came from sources other than SAP or required additional preparation, we also used the Excel4JPK and XML4JPK extensions, which allowed us to incorporate it into the reporting process.

The next step in preparing the JPK_KR_PD file for submission was assigning tax codes to accounts. This posed a particular problem when different types of transactions were posted to a single account—transactions that should be marked differently in the JPK_CIT file. From the perspective of the Ministry of Finance’s reporting requirements, the solution is to create additional analytical accounts. In practice, however, this was not always possible by the time the first file was due, particularly in Polish companies belonging to international groups that use a common, centrally managed chart of accounts. In companies managed in this way, it is not easy to change the account structure; therefore, in many cases, in cooperation with clients and their tax advisors, consultants proposed solutions that allowed for the submission of the first report while simultaneously implementing changes within the organization.

Despite the enormous challenges and pressure associated with decision-making, we also sought ways to automate some of the tasks involved in preparing JPK_KR_PD reports as part of the All for One JPK initiative. One example is income tax settlement (RPD): values can be calculated based on data from JPK, while the accountant retains the ability to manually verify and correct them. So it was not only about compliance with requirements, but also about ensuring that reporting was as efficient as possible and remained under the control of the finance department.

The final challenge was the submission itself. The standard MF tool for submitting JPK files (known as the JPK WEB Client) accepts files up to 100 MB. With the annual financial statements of a large company using SAP, this limit quickly proves insufficient, so the report would have to be split into multiple files and periods.

An alternative is sending data via an API, and JPK Transfer Hubhas proven effective in this role, allowing users to prepare and send files to the Ministry of Finance directly from SAP, receive UPO confirmation, and maintain a history of the entire process. In essence, the solution enables the handling of very large files, reducing the need to split them, which significantly streamlines substantive analysis.

Because the JPK Transfer Hub infrastructure operates on the All for One side in the SaaS model, we can adapt it more quickly to technical changes and new legal requirements. The entire process takes place through an intuitive dashboard, without the need to manually transfer files between different tools. During the first JPK_KR_PD submission, over 90 customers used our solution, and the largest file sent was nearly 40 GB.

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Author: Małgorzata Lutz, Solution Architect, All for One

“Given the scale of our operations, our tax data structure must be well-thought-out and organized, which is why our first JPK_CIT filing was a challenging undertaking for us. With OBI Polska’s large network of home improvement stores, wide product range, and huge number of transactions, every change requires working on multiple data sets and processes simultaneously."

Preparing the JPK_CIT report for submission required significant effort from both the finance and IT departments. Thanks to the support of All for One Poland, we were able to navigate the entire process efficiently and securely, and the reports were prepared and submitted on time.

Our collaboration with the All for One Poland team went exceptionally well. They are outstanding professionals who combine subject matter expertise with a practical approach and a high level of commitment. We particularly appreciate their willingness to learn about our processes and the specifics of our business, which definitely made our collaboration easier and allowed us to respond efficiently to emerging challenges. At every stage of the project, we could count on their commitment, quick response, and full availability. They provided us with real support both in our day-to-day work and in situations requiring a quick solution to a problem.

On a daily basis, we use the All for One JPK suite, along with Excel4JPK, VAT Change Analyzer, and JPK VAT-EU. These solutions complement each other well and create a cohesive environment for reporting, analyzing data, and preparing adjustments directly in SAP.

“We can wholeheartedly recommend working with All for One Poland as a competent, committed, and trustworthy partner. Their expertise, responsiveness, and flexible approach make it significantly easier for us to carry out the demanding processes involved in tax reporting." — says Beata Bergman, Manager of the Tax Department at OBI Polska.

“As the POLOmarket supermarket chain, we operate close to our customers, which is why the efficiency of our back-office processes is directly critical to the day-to-day operations of our business. The first JPK_CIT filing required extensive preparation, collaboration between the accounting and IT teams, and a thorough verification of the data. With the full support of All for One Poland, the project went smoothly, and we submitted the reports even before the required deadline. We were confident that the obligation had been fulfilled securely and without time pressure.”

In the SAP S/4HANA environment, we use the All for One JPK suite, along with the Excel4JPK and JPK VAT Change Analyzer extensions, which support data preparation, analysis, and report adjustments. All for One Partner Checker allows us to verify business partners directly in SAP, and All for One Payment Backlogs supports compliance with obligations related to payment backlogs. These solutions create a cohesive environment that matches the scale and pace of our retail network,” says Marzenna Reńska, Chief Accountant at Polskie Supermarkety.

“We’ve already completed our first JPK_CIT submission at Biscuit International, and although it required a lot of preparation, everything went smoothly. In an international company that manufactures cookies on a large scale, data is generated at many stages: from raw material procurement and production planning, through logistics, all the way to sales. Collecting such a wide range of data, standardizing it, and thoroughly verifying it turned out to be among the most challenging stages. The All for One Poland team helped us plan the entire process and addressed any questions that arose as they came up, ensuring that the shipment proceeded smoothly and on time.

The All for One JPK package helps us prepare reporting data from various sources. Meanwhile, All for One Partner Checker allows us to verify business partners on the white list of taxpayers directly in SAP. Together, these solutions effectively support our day-to-day tax and financial processes," says Gabriela Chlebowska, Chief Accountant at Biscuit International.

“The first submission of the JPK_KR_PD file marks the completion of an important phase, but work on data quality and the tool’s further development continues. The authorities are also clarifying how specific requirements should be interpreted following the receipt of the first reports and subsequent inquiries from taxpayers. Some of the additional data regarding fixed assets must be collected starting in 2025, even though the first submission of the file will likely be postponed by several years. The coming months may therefore require further organization of data and processes."

Today, however, we’re here first and foremost to celebrate. Our clients have done a tremendous job. We’ve been pleased to support them every step of the way—from the initial analyses, through configuration and filling in data gaps, to testing, file generation, and technical support for submission. “We support over 110 JPK_CIT projects in SAP; we treat each one individually and look for ways to work with the data that allow us to customize our clients’ systems without losing sight of their business needs,” says Jacek Szlachta, Solution Architect at All for One.