The implementation date of SAF_CIT reporting is inexorably approaching. One of the important elements is the specificity of solutions for entities preparing financial statements based on International Financial Reporting Standards/International Accounting Standards.
According to Article 66 sec. 2 of the Polish Act of 29 October 2021 amending the Personal Income Tax Act, the Corporate Income Tax Act and certain other acts, it will be mandatory to submit SAF_CIT files after the tax year following the date of:
● 31 December 2024 – in the case of:
- tax capital groups,
- taxpayers and companies which are not legal persons, whose income earned in the previous tax year or financial year, respectively, exceeded the equivalent of EUR 50 million converted into PLN at the average EUR exchange rate announced by the National Bank of Poland on the last business day of the previous tax year or financial year, respectively;
● 31 December 2025 – in the case of taxpayers and companies that are not legal persons, obliged to send the JPK V7M file;
● December 31, 2026 – in the case of other taxpayers and companies that are not legal persons.
In other words, for the largest taxpayers and tax capital groups whose tax year begins on 1 January 2025, the first SAF_CIT reporting will take place by 31 March 2026. and will include data for 2025.
On the other hand, § 5 section 2 of the Decree of the Minister of Finance on additional data to be added to the books of account to be transferred under the Corporate Income Tax Act indicates that in the case of taxpayers preparing financial statements pursuant to Article 45 section 1a and 1b of the Polish Accounting Act, in accordance with the International Accounting Standards, the International Financial Reporting Standards and the related interpretations published in the form of regulations of the European Commission, referred to in Article 2 sec. 3 of this Act, the books for the tax year that begins after 31 December 2024 and before 1 January 2026 may not be supplemented with additional data, referred to in § 2 section 1 point 3.
§ 2 section 1 point 3 of the Decree refers to markers identifying ledger accounts, therefore in the SAF_CIT file for 2025, such entities may omit data on markers identifying ledger accounts.
In the set of ministerial “questions and answers”, it was asked whether such units should prepare their own descriptions. The Ministry points out that until a separate dictionary is available, entities using IRS/IFRS are not obliged to assign tags to accounting accounts.
Nota bene, a provision is currently being processed in the Sejm, according to which the Minister of Finance may issue a regulation to exempt taxpayers from the obligation to provide records of fixed assets and intangible assets (SAF_ST_KR files).
Important: entities with a postponed tax year will apply the rules in accordance with their choice of settlement period. This follows directly from the provision indicated at the beginning.
