Control ratios for calculation of insurance premiums (DAM) 2021

In connection with this, the control ratios for the DAM have changed

As specialists from the Federal Tax Service of Russia noted in their letter, the current control ratios of the DAM were approved taking into account the standard rate of contributions for compulsory insurance for all employers. But in the spring of 2021, Federal Law No. 209-FZ dated July 24, 2007 “On the development of small and medium-sized businesses in the Russian Federation” was adopted, according to which, from April 1, 2020, payers of insurance premiums recognized as small or medium-sized businesses received the right to pay insurance premiums at a reduced rate of 15%:

for compulsory pension insurance - 10%;
for compulsory social insurance in case of temporary disability and in connection with maternity - 0%;
for compulsory health insurance - 5%.

The new procedure applies to wages for April 2020 and subsequent months. For March, insurance premiums are charged at the regular rate.

In this regard, tax authorities clarified the control ratios in the DAM 1.84, 1.138 and 1.140, and also introduced new control ratios 1.193–1.199 and 2.8–2.10. They will help check the correctness of filling out the DAM regarding payments to employees and other individuals in the amount of more than 1 minimum wage, which are subject to reduced insurance premiums when submitting the DAM for the first half of the year (6 months) of 2021.

Sick leave

The Federal Tax Service clarified that most indicators must be assessed for each payer tariff code: 01, 06, 07, 10, 11, 13-19 (Appendix No. 5 to the Procedure for filling out the calculation form, approved by Federal Tax Service order No. ММВ-7- dated September 18, 2019 11/470).

Most likely, such an explanation is associated with the appearance of line 002 to indicate the payment attribute.

The Federal Tax Service has introduced a ratio for the new line 015. It shows the number of individuals for whom contributions are calculated, reflected in Appendix No. 2 to Section 1 of the RSV (this is the Calculation of the amounts of insurance contributions for compulsory social insurance in case of temporary disability and in connection with maternity to Section 1 ). Here, according to the Constitutional Code, they verify that the number of people since the beginning of the year should not be less than the same figure for the previous period.

If line 015 is completed, in the corresponding column of line 020 the value of taxable payments must be greater than zero.

New KS have appeared to check the reflection of payments to foreigners in the DAM (line 055). Assessing the reality of the indicator depends on whether such payments took place.

SITUATION	SOLUTION
There were no payments to foreigners during the reporting period	if gr. 2 pp. 055 adj. 2 R.1 + gr. 3 pp. 055 adj. 2 R.1 + gr. 4 pp. 055 adj. 2 R.1 = 0, then ((gr. 2 p. 060 app. 2 R.1 + gr. 3 p. 060 app. 2 R.1 + gr. 4 p. 060 app. 2 R.1) = (gr. 2 p. 050 app. 2 R.1 + gr. 3 p. 050 app. 2 R.1 + gr. 4 p. 050 app. 2 R.1) × corresponding to the value of field 001 app. 2 R. 1 tariff of insurance premiums) ≤ (group 2 p.015 appendix 2 R.1 + group 3 p.015 appendix 2 R.1 + group 4 p.015 appendix 2 R.1)/3 × 0 .05 rub.
Payments to foreigners were	if gr. 2 pp. 055 adj. 2 R.1 + gr. 3 pp. 055 adj. 2 R.1 + gr. 4 pp. 055 adj. 2 R.1 0, then (gr. 2 p. 060 appendix 2 R.1 + gr. 3 p. 060 app. 2 R.1 + gr. 4 p. 060 appendix 2 R.1) ≥ (gr 2 page 050 appendix 2 R.1 + group 3 page 050 appendix 2 R.1 + group 4 page 050 appendix 2 R.1) × 1.8%.

New control ratios

Earlier, by letter dated 02/07/2020, new control ratios were introduced for new temporary tariff codes and categories of insured persons. These are the codes:

For reduced insurance premiums for part of payments exceeding 1 minimum wage - 20.
For insured individuals - citizens of the Russian Federation, part of the payments from 1 minimum wage - MS.
For foreigners and stateless persons insured in the OPS system who temporarily reside in Russia, as well as foreigners or stateless persons temporarily residing in the Russian Federation who have been granted temporary asylum - VZHMS.
For foreigners and stateless persons who are temporarily staying in the Russian Federation (with the exception of highly qualified specialists) - VPMS.

The Federal Tax Service admits that these codes may become permanent. In this regard, additional formulas have been added to the control ratios for insurance premiums:

for payer rate code;
for the category code of the insured person.

Changes were approved both in the CS for calculation sections and in the inter-documentary CS. In particular, DAM data corresponds with information about the payer in the SME register at the beginning of each month. All KS are traditionally designed in the form of a table, which contains information about the KS itself, violation of the norms of the Tax Code of the Russian Federation and other laws.

How to reflect the amounts of expenses reimbursed by the territorial bodies of the Social Insurance Fund?

The calculation of the amounts of contributions for compulsory social insurance in case of temporary disability and in connection with maternity is given in Appendix 2 to Section. 1 calculation of insurance premiums. As a general rule, the data is reflected (Section XI of the Procedure for filling out the calculation):

total since the beginning of the settlement (reporting) period;
for the last three months of the billing (reporting) period, as well as for the first, second and third months of the last three months of the billing (reporting) period.

In appendix 2 to section. 1 calculations for insurance premiums are given	Number of insured persons (line 010)
	Payments calculated in favor of individuals and amounts not subject to contribution (lines 020 and 030)
	Payments exceeding the maximum base for contributions to insurance in case of temporary disability and in connection with maternity (line 040). In 2021, the maximum base value for this type of insurance is RUB 755,000. (Resolution of the Government of the Russian Federation dated November 29, 2016 No. 1255)
	Base for calculating insurance contributions for compulsory social insurance in case of temporary disability and in connection with maternity (line 050)*
	Calculated amount of contributions (line 060)
	The amount of expenses for the payment of insurance coverage and the amount of these expenses that were reimbursed by the Social Insurance Fund (lines 070 and 080)
	Insurance premiums (line 090): – either the amount to be paid; – or the amount of excess of expenses incurred over the amount of calculated contributions

* Due to the fact that when calculating insurance premiums from payments and remunerations for certain categories of persons, tariffs that differ from the general ones are used, from the base for calculating insurance premiums the policyholder must separately allocate bases in relation to the amounts of payments and other remunerations:

produced by pharmacy organizations and individual entrepreneurs who have licenses to conduct pharmaceutical activities, to individuals who, in accordance with Federal Law dated November 21, 2011 No. 323-FZ, have the right to engage in pharmaceutical activities or are allowed to carry them out (line 050);
insurance premiums paid by payers to crew members of ships registered in the Russian International Register of Ships (line 052);
produced by individual entrepreneurs using PSNO, to individuals engaged in the type of economic activity specified in the patent (line 053);
accrued in favor of foreign citizens and stateless persons temporarily staying in the Russian Federation (except for citizens of EAEU member states) (line 054).

The Federal Tax Service in Letter No. BS-4-11/ [email protected] clarified that the calculation includes information that serves as the basis for the calculation and payment of insurance premiums for reporting periods starting from the first quarter of 2017, about the amount of the payer’s expenses for payment insurance coverage for compulsory social insurance in case of temporary disability and in connection with maternity, which are reimbursed by the territorial bodies of the Social Insurance Fund.

The amounts of expenses reimbursed by territorial bodies of the Social Insurance Fund for reporting periods before 2021 are not reflected in the calculation.

When filling out line 080 of Appendix 2 “Calculation of the amounts of insurance contributions for compulsory social insurance in case of temporary disability and in connection with maternity” to section. 1 of the calculation, you should follow clause 11.14 of the Procedure for filling out the calculation.

Line 080 is filled out by policyholders whose current account received funds from the Social Insurance Fund to reimburse expenses incurred for the payment of insurance coverage.

For this line, in the appropriate columns, you should show the amounts of the payer’s expenses reimbursed by the territorial bodies of the Social Insurance Fund for the payment of insurance coverage for compulsory social insurance in case of temporary disability and in connection with maternity from the beginning of the billing period:

for the last three months of the billing (reporting) period;
for the first, second and third months of the last three months of the billing (reporting) period, respectively.

So, if the payer’s expenses incurred in one reporting period are reimbursed in another reporting period, these amounts must be reflected in the calculation for the reporting period in relation to the month in which the territorial bodies of the Social Insurance Fund carry out the specified reimbursement.

For example, in March 2021, the organization’s current account received money from the Social Insurance Fund to reimburse benefits for January and February. In this case, the entire amount received is reflected on line 080 for the third month (March).

For your information:

The indicator of line 080 participates in the calculation of the indicator of line 090. The value of this line is added to the difference between the indicators of lines 060 and 070.

The indicator in column 2 on line 090 is determined by the formula:

Column 2 on line 090 of Appendix 2 to Section. 1

Column 1 on line 060 of Appendix 2 to Section. 1

—

Column 1 on line 070 of appendix 2 to section. 1

Column 1 on line 080 of Appendix 2 to Section. 1

Columns 4, 6, 8, 10 on line 090 are calculated and filled in in the same way.

The amount of contributions subject to payment or reimbursement at the end of the reporting (calculation) period is reflected on line 090:

or with the sign “1”, if it is positive and the payer must pay contributions to the budget;
or with sign “2”, if it is negative, that is, the cost of benefits is greater than the calculated contributions.

From the editor:

The procedure for financial support for insurers' expenses for payment of insurance coverage for temporary disability and in connection with maternity, both before and after January 1, 2021, is regulated by Federal Law No. 255-FZ dated December 29, 2006 “On compulsory social insurance in case of temporary disability and in connection with with motherhood." The issue of the procedure for offsetting expenses for sick leave and maternity benefits was considered in No. 7, 2021.

Rules for submitting RSV

Employers submit this report to the Federal Tax Service at the end of the year and quarterly. The new reporting form was approved by order of the Federal Tax Service of Russia dated September 18, 2019 No. ММВ-7-11/470. Its policyholders will be handed over for the first time in the first quarter of 2021. It has reduced the total number of indicators by about 30%, which means it has become easier to fill out.

Report on insurance premiums no later than the 30th day of the month following the reporting (calculation) period. In 2021, the deadlines for submitting this form look like this:

for the first quarter - until 04/30/2020;
6 months before 07/30/2020;
9 months - until October 30, 2020;
for 2021 - until 02/01/2021 (postponement from January 30, Saturday).

What to follow

In 2021, the control ratios of the DAM were first approved by letter of the Federal Tax Service of Russia dated December 29, 2017 No. GD-4-11/27043. The full text of this multi-page document can be found on the official website of the Federal Tax Service of Russia via a direct link here. And then - by letter of the Federal Tax Service dated 02/07/2020 No. BS-4-11/2002 “On the control ratios of the form for calculating insurance premiums, approved by order of the Federal Tax Service of Russia dated 09/18/2019 No. ММВ-7-11/470...”.

Keep in mind that by letter of the Tax Service dated October 17, 2019 No. BS-4-11/21382, the specified ratios for the DAM were supplemented.

These new control ratios for calculating insurance premiums in 2020 call for comparing the amount of payments within the framework of the labor relationship - that is, the difference in columns 210 and 230 of subsection 3.2 of section 3 for each month.

The indicator should not be less than:

Minimum wage;
average salary in the region by economic sector for the previous billing period.

Otherwise, there is an underestimation of the base for calculating insurance premiums.

If at least one of these ratios is not met, the Federal Tax Service will consider that the base for insurance premiums is underestimated. Then, on the basis of clause 3 of Art. 88 of the Tax Code of the Russian Federation will send a message about identified errors/contradictions/inconsistencies with a requirement to provide the necessary explanations within 5 days or make appropriate corrections within the prescribed period.
If, after reviewing the provided explanations and documents, or in their absence, the contribution payer is found to have understated the contribution base, other tax control measures are possible to identify possible violations.

Also see “Control ratios for calculating 6-personal income tax in 2021.”

Why are control ratios needed?

Control ratios for any reporting form are a method of mathematical data verification that reflects the correctness of the information entered into the report by comparing certain indicators. Data is compared both within the form itself and with other reports.

Tax officials create and supplement a table comparing the indicators of the insurance premium calculation form and send it to the territorial offices so that the territorial Federal Tax Service Inspectors check the correctness of the data specified in the payers’ documents. The information is not kept secret: the policyholders themselves have the right to use the developed indicators for self-checking before submitting the calculation. Previously, the Federal Tax Service of Russia has already published a memo for payers of insurance premiums, which contains sufficient information on the procedure for their calculation and payment.

Control ratios in the report: calculation of insurance premiums

The data for verification is presented in the form of a voluminous table. It contains more than 300 internal control relationships within the calculation and two inter-document ones. In particular, the control ratios of 6-NDFL and the calculation of insurance premiums 2021. For example, the first of them sounds like this: “the obligation to provide a calculation of insurance premiums in the case of providing 6-NDFL.” This means that all employers who are required to report under 6-NDFL are also required to report on insurance premiums. Even if the calculation turns out to be zero.

We will dwell in more detail on a small part of it, inter-document relationships, in order to understand how to use it. So, these indicators look like this:

Document	№	KS	Violation	Actions of the Federal Tax Service
RSV. 6-NDFL (in relation to the parent organization)	2.1	It is necessary to provide RSV in case of submitting 6-NDFL	Request for reporting
RSV. 6-NDFL (for taxpayers without separate sections, not for individual entrepreneurs on a patent and UTII)	2.2	Art. 020 rub. 1 6-NDFL - art. 025 rub. 1 6-NDFL >= art. 050 gr. 1 other 1.1 rub. 1 RSV	The amount of accrued income of the taxpayer is less than the base for calculating insurance premiums	Request for explanation or correction
RSV, information from the FSS of Russia	2.3-2.5	Gr. 3-5 tbsp. 80 applications 2 r. 1 RSV = the amount of funds allocated by the Social Insurance Fund for reimbursement of expenses for insurance payments in 1-3 months of the reporting period	The amount of reimbursed expenses is more than the allocated amount	Same

It is not difficult to understand what the first line in this table means; this has already been discussed above. But the second line already contains a real comparative indicator, and we will dwell on it in more detail. So, tax authorities argue that the difference between line 20 of section 1 and line 25 of section 1 in the 6-NDFL declaration must be greater than or equal to the data reflected in line 50 of group 1 of subsection 1.1 of the calculation of insurance premiums. What's in these form fields:

page 20 rub. 1 is the amount of accrued income;
page 25 rub. 1 - these are accrued dividends, which are included in the amount of income.

Obviously, since insurance premiums are not charged on the amount of dividends, it is deducted in order to obtain the taxable base for them, which is indicated on page 050 gr. 1 other 1.1 RSV. If the data does not match, it means the payer made a mistake and will be sent a request for clarification. But this is not the only option. If discrepancies are identified in the document, tax authorities have the right to immediately draw up an act of violation in accordance with the provisions of Article 100 of the Tax Code of the Russian Federation and hold the payer accountable. If the payer himself discovers the error after the payment has been submitted, he has the right to submit an updated form.

What control ratios are used when checking calculations of insurance premiums?

The Federal Tax Service has published clarifications regarding the use of control ratios used when checking calculations of insurance premiums. These clarifications are provided in letter No. BS-4-11/8659 dated May 26, 2020.

Now, to check the correctness and reliability of calculations for insurance premiums, tax authorities use control ratios, which are given in the letter of the Federal Tax Service dated December 29, 2017 No. GD-4-11 / [email protected]

In particular, tax authorities monitor the amount of calculated insurance premiums for each month, specified in subsection 3.2.1 of section 3 of the calculation of insurance premiums.

This amount is determined based on the base for calculating insurance premiums from the beginning of the billing period to the end of the corresponding month and the rate of contributions minus the amounts of contributions calculated from the beginning of the billing period to the previous calendar month inclusive.

In this case, the calculation will not be accepted if it contains unreliable data:

on the amount of payments and other remuneration in favor of individuals;
on the basis for calculating insurance premiums;
about the amount of insurance premiums.

Also, the calculation is considered unsubmitted if it contains inaccurate personal information identifying employees.

In connection with the publication of the Federal Tax Service order N ММВ-7-11/ [email protected] , which approved the form of calculation for insurance premiums, used from the first quarter of 2021, changes were made to the control ratios of the indicators for calculating premiums. However, all changes to control ratios are purely technical. Therefore, in fact, the control ratios have not changed.

BUKHPROSVET

The calculation of insurance premiums is submitted to the Federal Tax Service no later than the 30th day of the month following the first quarter, half year and nine months of the calendar year (Article 423 of the Tax Code of the Russian Federation). The calculation is submitted to the Federal Tax Service at the location of the organization and at the location of separate divisions of organizations that accrue payments and other remuneration in favor of individuals.

Calculations for insurance premiums in electronic form are required to be submitted by employers whose number of employees in whose favor payments are accrued for the billing (reporting) period exceeds 10 people. For up to 10 people, insurance premiums can be calculated on paper. Responsibility for failure to submit calculations for insurance premiums, as well as for violation of the deadlines for their submission, is established in accordance with Art. 119 of the Tax Code of the Russian Federation.

The maximum fine cannot exceed 30% of the amount of contributions not paid according to the calculation. The minimum fine is set at 1,000 rubles. If the delay in submitting the payment exceeds 10 days, his bank account may be blocked (clause 1, clause 3, article 76 of the Tax Code of the Russian Federation). The organization will not be able to open a new account (Clause 12, Article 76 of the Tax Code of the Russian Federation). The tax authorities will make a decision to cancel the blocking no later than one day following the day the calculation is submitted.