Tax risks when accounting for advance reports


When is it necessary to prepare an advance report?

An advance report is drawn up when funds are issued in advance to accountable persons of an organization or individual entrepreneur.

If the employee spent his own funds, and the company subsequently reimbursed him, there is no need to prepare a report. The main condition for the preparation of this document is the issuance of funds in advance.

Accountable persons in 2021 include employees working in the organization (or individual entrepreneur):

  • under an employment contract;
  • under a civil contract (GPC).

The obligation to draw up a report in relation to non-staff employees working in the organization on the basis of GPC agreements is confirmed, among other things, by the letter of the Bank of Russia dated October 2, 2014 No. 29-Р-Р-6/7859.

It is not permitted to issue or transfer the issued funds to other persons, for example, employees of the counterparty or close relatives. Only the employee to whom they were issued is required to report for the funds spent.

How long should expense reports be kept?

In accordance with Part 1 of Art. 29 of Federal Law No. 402-FZ, advance reports must be stored for 5 years after the reporting period. Each organization chooses the procedure for storing expense reports independently. As a rule, advance reports with attached supporting documents are filed in chronological order or quarterly.

Please note that the Central Bank has amended Directive No. 3210-U (Central Bank Directive No. 5587-U dated October 5, 2020), thereby simplifying the rules for issuing money for reporting.

These changes came into force on November 30, 2020:

  • in the application for the issuance of accountable money, it is not necessary to indicate the amount of the advance and the period for which the accountable amounts are issued. You can also issue one order for several cash payments to one or more employees.
  • The organization and individual entrepreneur have the right to independently set the deadline within which the accountable must submit an advance report.
  • Even those employees who have not reported on past amounts received are entitled to receive funds. The requirement that an employee must account for previously issued amounts was removed from clause 6.3 of the Central Bank Instructions No. 3210-U dated March 11, 2014.
  • Also, starting from 2021, accountable money can be transferred to an employee’s salary card. But then the details of the salary card to which the money is transferred must be reflected in the director’s order, or the employee must write them down in the application for reporting. And so that the tax authorities do not decide that this is an employee’s salary and do not require personal income tax to be calculated from the accountable amount, payment orders will need to be filled out in a special way. In field 24 “name of payment”, specify that the transferred funds are accountable. For example, you can make entries such as: advance payment for business needs or advance payment for travel expenses, and so on.
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