JPK_KR_PD for PIT clients on full books: the partnership sends the file, the partners pay the tax

The Clients the JPK_CIT Conversation Skips

When accounting offices talk about JPK_CIT, they talk about companies: a limited liability company, a CIT-8, a March deadline. I wrote that version last week in JPK_CIT for 2026 and the chart of accounts.

But most offices also carry a group that sits in between: PIT taxpayers on full books. General partnerships (spółki jawne) of individuals that crossed the revenue threshold for full accounting years ago. A few civil and professional partnerships. Sole traders who moved to full books by choice or because they had to.

They file JPK_KR_PD too, under the PIT Act rather than the CIT Act. And the rules differ in three places that matter for planning: who sends the file, when they start, and what goes in the tax section.

Stage One or Stage Two Depends on the VAT Return

First question: which year does a given client start? For PIT taxpayers and partnerships on full books, the stage follows the VAT return:

• JPK_V7M (monthly VAT): the first JPK_KR_PD covers 2026. In principle JPK_ST_KR, the fixed-asset register, comes with it for the same period. A draft MF regulation from August would exempt partnerships (along with CIT taxpayers) from sending it for 2026–2028, but not sole traders on full books. Details in JPK_ST_KR and the exemption trap.
• JPK_V7K (quarterly VAT): the first file covers 2027.

So the same office can have two partnerships with near-identical books, one already in its first reported year and the other not. Some clients will have switched between monthly and quarterly VAT at some point. I'd check each client's current filing rather than trust memory.

The deadline under the current wording of art. 24a of the PIT Act is the annual return deadline: 30 April 2027 for 2026. A government bill (UD350, now Sejm print 2445) would move that to 31 July after the tax year. At the time of writing I couldn't confirm it had been passed. Don't plan your spring around 31 July until it's in the Journal of Laws.

The Partnership Sends the File, the Partners Pay the Tax

This is where offices most often go wrong, because it runs against how the rest of the partnership's taxes work.

A general partnership of individuals isn't an income tax payer. Its partners are, each in their own PIT-36 or PIT-36L, according to their share in the profit. You'd expect the partners to send the file. They don't. In an answer from 28 April 2026, quoted by podatki.biz, the Ministry of Finance said the books, and the obligation to send them, belong to the entity that keeps them. The file shows values for the partnership as a whole, and nothing is broken down per partner. Partners who are individuals don't send a separate JPK_KR_PD for their share.

Two consequences follow:

1. The RPD section is zero. The income tax settlement node (RPD) is filled with zeros for a partnership of individuals, because the partnership has no income tax to settle. A partner that is itself a CIT taxpayer, such as a limited liability company in a spółka jawna, reports its share of revenue and costs in its own file, proportional to its profit share.
2. The account markers still go in. The partnership's accounts carry their markers like any other books, including the tax ones. The tax office gets the partnership's view of which costs are deductible. It just doesn't get the calculation that turns that into each partner's tax.

The Spreadsheet That Becomes Visible

Why does the second point matter? In most offices, the step from a partnership's books to the partners' returns lives in a spreadsheet. Take the year's result, subtract the non-deductible costs, apply each partner's share, adjust for anything personal, copy the figures into PIT-36L.

Until now, nobody outside the office saw that spreadsheet next to the books. From 2026, the tax office has the books with their tax markers in one file and the partners' returns in another. Say the markers on the partnership's accounts put 18 400 zł of representation as non-deductible, and the spreadsheet behind the partners' returns excluded 11 000 zł. A risk-analysis system can now find that difference without asking anyone.

Where does the drift come from? Mostly the same places as in companies, just with PIT article numbers:

• Representation and advertising on one account. Representation costs aren't deductible under art. 23 sec. 1 point 23 of the PIT Act; advertising generally is.
• Cars. A mixed-use passenger car is deductible at 75% (art. 23 sec. 1 point 46a). One running-costs account for that car and a company van can't carry one honest marker.
• Interest and penalties. Loan interest next to tax-arrears interest, contractual penalties next to fines.

Then there's one that only partnerships have: the profit share changed during the year. A partner joined in June, or the agreement moved from 50/50 to 60/40. The books don't care. The allocation sheet does, and it's the only place that calculation exists.

Sole Traders on Full Books

Sole traders on full books are simpler in one respect: the books and the return belong to the same person, so there's no allocation step. The markers still run into the same mixed-account problem, though. And full-books sole traders tend to have more costs that brush up against private life than companies do: a car used privately, a phone, a home office. More accounts, in other words, where the tax treatment isn't uniform.

For them, the RPD section isn't zero. The settlement goes into the closing file, the same way the 4 October post describes for companies, and the interim files carry zeros there. Which means a January–September trial file will look complete while missing the hardest part.

A Rough Count for a Typical Office

Say an office has 30 PIT clients on full books: 18 general partnerships and 12 sole traders, of which 20 file VAT monthly. That's 20 files for 2026 and the other 10 a year later.

If a typical client has 180 analytical accounts with movement, marking the straightforward ones at a minute each takes three hours per client. That's 60 hours for the 2026 group. Then come the mixed accounts. Split one in October and you re-book nine months; leave it until April and it's twelve, in the same weeks as everyone's PIT-36L.

The partnership work comes on top: for each of the 18 partnerships, one check that the non-deductible total implied by the markers matches the allocation sheet. When the books and the sheet agree, it's quick. When they don't, it gets long fast.

What an Agent Does Here

The agent can:

• go through the client list and sort every full-books PIT client by VAT filing (V7M or V7K), legal form, and whether any partner is a CIT taxpayer, so you know who files for 2026, who for 2027, and whose partner needs its own RPD entries;
• generate a January–September trial JPK_KR_PD for the 2026 group and list accounts without markers;
• read entry descriptions on cost accounts and flag accounts that look mixed;
• compare the non-deductible total implied by the proposed markers with the figure in each partnership's allocation sheet, and flag partnerships where the profit share changed during the year.

The accountant keeps:

• every decision about tax treatment;
• the allocation between partners and the partners' returns;
• the closing file and its submission.

That's the line I draw in every accounting project: the agent prepares the list, a person signs. More on that in AI agents and liability. If you also have PIT clients on the revenue and expense ledger, their file is a different structure with different gaps; see JPK_PKPiR for 2026.

One List to Make This Month

Every PIT client on full books, two columns: V7M or V7K and partnership or sole trader. Mark the partnerships whose profit share changed this year. That list tells you how many 2026 files you have and which ones need the most attention.

If you want to see how an agent builds that list from your ERP and client files, write to me. I'll go through it with one of your partnerships and tell you honestly whether automating it is worth it at your scale.