The Polish Ministry of Finance has opened a tax consultation concerning changes to JPK_KR_PD. The proposal provides for an extension of the PD tax marker catalogue and the addition of new fields to the RPD node, with comments accepted until 15 September 2026.
The changes concern how tax differences are reported
At first glance, the proposal may appear to be a purely technical change relating to account mapping. In practice, however, it affects how the tax authority will see the difference between the accounting result and the taxable base.
The proposal does not change the substantive tax rules. It changes the level of detail with which individual items will be reported in the JPK_KR_PD structure.
The catalogue of tax markers will become more detailed
The draft provides for a significant extension of the PD marker catalogue.
Tax-exempt income and non-deductible expenses are to be divided into more detailed categories. Separate markers are also proposed for selected tax reliefs and preferences, including R&D relief, IP Box, bad debt relief, donations and virtual currencies.
In practice, this means less scope for reporting different items under broad or general categories.
The RPD node will reflect the path to the taxable base
Another important element of the proposal is the expansion of the off-balance-sheet reporting layer.
The published catalogue of RPD fields, from K_1 to K_14, is intended to reflect the full sequence of adjustments leading from the accounting result to the taxable base and tax liability.
The proposal also covers entities reporting under IFRS, for which it will be particularly important to ensure consistency between the logic of tax adjustments and the reporting structure.
Greater detail means greater importance of correct mapping
The more detailed the tax marker catalogue becomes, the less room there is for discretionary classification.
As a result, decisions made when configuring accounting systems and mapping accounts will become even more important for correct JPK_KR_PD reporting.
The issue therefore goes beyond simply assigning new technical labels. Businesses should ensure that the logic used in their accounting records corresponds with the way data must be presented in the JPK structure.
What should be reviewed before the consultation closes?
Before 15 September 2026, businesses should verify:
• whether their current account mapping can be translated into the new, more detailed markers, including off-balance-sheet positions,
• whether tax reliefs and preferences can be clearly assigned to the appropriate markers, rather than remaining in general categories,
• whether, for entities reporting under IFRS, the adjustment logic is consistent with the RPD node structure.
Where the proposed solutions raise concerns, the consultation period still provides an opportunity to submit comments. The deadline for submissions is 15 September 2026. Once the process is completed, businesses will need to adapt their mapping to the final version of JPK_KR_PD.
Please contact us if your organisation requires support in analysing the proposed changes or reviewing its JPK_KR_PD data mapping.
We support businesses in analysing JPK_KR_PD structures, mapping charts of accounts, assigning tax markers and reviewing the logic of adjustments leading to the taxable base. We also help assess the impact of proposed changes and prepare comments during the consultation process.
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