Filling out the “type of income code” field if money is accountable: explanations of the Central Bank 2021

Additional reporting documents

Documentation of settlements with accountable persons is not always limited to only an application, cash documents and an advance report with attached supporting documents.

Additional accountable securities include:

• a memo (if the employee went on a business trip by car), a report (when making entertainment expenses), other necessary explanatory documents;
• an order to withhold accountable amounts - it is needed if the accountable person has not submitted an advance report and has not returned the money (Article 137 of the Labor Code of the Russian Federation);
• notification (message) and order to forgive an accountable debt - are issued if the employer decides not to collect the specified amounts from the employee (clause 2 of article 145 of the Civil Code of the Russian Federation, clause 6 of article 226 of the Tax Code of the Russian Federation).

Tax risks of documentary reporting errors

If there are errors in the documents of accountable persons or supporting documents are not attached to the advance report, various types of risks may arise, including tax ones:

In addition to tax risks, other negative consequences are possible. For example, if inventory items purchased with accountable money without supporting documents are not capitalized, a claim may be brought against the accountable person for causing damage to the company (Resolution of the Administrative District of the North Caucasus District dated October 5, 2017 No. A32-12049/2015).

New rules for transferring salaries.

From 01.06.2020, institutions paying wages or other income to a citizen will be required to indicate in payment documents (Part 5.1, Article 70 of the Federal Law of 02.10.2007 No. 229-FZ “On Enforcement Proceedings” (hereinafter referred to as Federal Law No. 229-FZ) ) as amended by Federal Law No. 12-FZ dated February 21, 2019):

• the amount collected under the writ of execution (Part 3 of Article 98 of Federal Law No. 229-FZ as amended by Federal Law No. 12-FZ of February 21, 2019);
• the corresponding code of the type of income - if restrictions are established on the wages or other income paid to the employee (Article 99 of Federal Law No. 229-FZ) and (or) penalties cannot be applied to them (Article 101 of Federal Law No. 229-FZ) .

Taking into account the amendments, banks will be able to automatically write off debts for alimony, loans, debts and other payments from wages, but will not deduct amounts that cannot be written off by law.

From 06/01/2020 this list is clause 1 of Art. 101 of Federal Law No. 229-FZ was supplemented with clause 18, according to which funds of one-time material or financial assistance allocated to citizens affected by an emergency situation will not be subject to recovery:

• in connection with the loss of essential property;
• as a one-time benefit to family members of citizens who died as a result of an emergency;
• whose health has been harmed to varying degrees of severity.

By definition of the Constitutional Court of the Russian Federation dated January 17, 2012 No. 122-O-O, income received by a citizen outside of economic activity (income from one-time transactions for the sale of real estate - an apartment, a land plot, a garden house, etc.) is excluded from collection.

“1” – when paying wages and transferring other income (for example, payments under the GPA), for which a limit has been established for deducting debts;

“2” – when transferring amounts from which debts cannot be collected (with the exception of compensation for harm to health and compensation from budgets for citizens injured in radiation and man-made disasters);

“3” – when paying amounts that are exceptions mentioned above.

You will need to indicate the new code in field 20 of the payment order “Base of payment” from 06/01/2020. In this case, it will become impossible to transfer both salary and compensation in one order.

Ways to reduce risks

Several actions will help reduce the risks of errors in documenting reports to the employer:

• Detail the procedure for preparing sub-reports in local acts.

Include a condition on the possibility of issuing money on account and returning unused accountable amounts, both in cash and in non-cash forms, into internal local acts (accounting policies, Regulations on the issuance of accountable amounts or other internal documents).

Also provide that with non-cash payments, accountable amounts are transferred to the personal or salary cards of employees from the employer’s current account.

Don’t forget to specify the deadline for submitting an advance report on the sub-account transferred to the employee’s card - such a deadline is legally established only when issuing a cash sub-account. This is necessary to stop abuse by employees.

Familiarize employees with their signature with the company's established accountability rules.

• Issue an order regarding accountable persons.

In the order, record:

• a list of employees entitled to receive money on account;
• the maximum amount allowed for issuance;
• deadlines for which accountable funds are issued.

Typically, such an order is issued at the beginning of the year for 12 months or a longer period. If necessary, changes and additions are made to it.

• Control the purpose of payment in payment slips for the transfer of accountable funds.

To ensure that controllers do not confuse the account listed on an employee’s card with salary income, and that such a transfer does not arouse suspicion among bankers, when issuing payment orders, it is important to ensure the proper wording of the purpose of the payment (field 24):

Systematic work with employees will help reduce risks - give them reminders about the deadlines for reporting on accountable amounts and lists of documents attached to expense reports for different situations, develop templates for applications for the issuance of money, and conduct training for employees on accountable rules.

Peculiarities

Today, the issuance of accountable amounts for an employee of an enterprise has a number of features that should be taken into account. So, the purpose of the payment plays a big role. It must always be indicated. In the payment order you need to write “Transfer of accountable funds”. And the employee writes a statement before each such transfer. To report on the finances spent, the employee presents to the employer simple receipts, tickets and sales receipts. In addition, you can display ATM receipts and original slips. These documents may fade over time, so it is recommended that you make copies of them.

The employer can reimburse the employee’s personal money spent on the needs of the enterprise. This will also require documents in the form of checks and receipts. Another significant question: within what period is a person obliged to return unspent money? The legislation does not establish any time frames here, but they must be indicated by the employer himself, at his own discretion. Usually this is three days. If the employee does not return the money on time, the tax service will deduct personal income tax from this money. Refunds are made both through the cash desk in cash and by bank transfer to the company's account.

A company that makes such transfers to an employee’s salary card must carry them out as follows:

• D-t 71, K-t 51.
• D-t 10, K-t 60.
• D-t 60, K-t 71.
• D-t 50, K-t 71.

Accountable document flow and new Directive of the Central Bank of the Russian Federation No. 5348-U

From the end of March 2021, when issuing accountable money, companies must be guided by the new rules for cash payments (Instruction of the Central Bank of the Russian Federation dated December 9, 2019 No. 5348-U “On the rules for cash payments”). They did not radically change the previous norms from Directive No. 3073-U dated October 7, 2013, but partially corrected them.

The new instruction prescribes cash payments between companies, individual entrepreneurs and individuals using cash received at the cash desk of a participant in cash payments from his bank account (Central Bank Letter No. 45-19/5013 dated 06/04/2020).

It turns out that it is possible to issue cash on account from cash proceeds, but immediately issuing an unspent accountable advance returned by one employee to the cash desk to another accountable person will become a risky procedure that will attract the attention of controllers. The penalty for such a violation is for officials from 4,000 to 5,000 rubles, for companies from 40,000 to 50,000 rubles. (Part 1 of Article 15.1 of the Code of Administrative Offenses of the Russian Federation).

In such a situation, you will have to first hand over the money to the bank, and then withdraw it and only then give it to the accountant.

Will this procedure affect the accountable document flow? Most likely no. There will be more work for cashiers and accountants to prepare cash receipts and expenses, but the set of documents for the accountant will not change.

Is it possible to issue a report to an employee’s card?

The legislation of the Russian Federation does not have a separate regulatory document establishing the procedure for issuing accountable funds to an employee’s card. The Bank of Russia directive “On the procedure for conducting cash transactions for legal entities and individual entrepreneurs” dated March 11, 2014 No. 3210-U, known to accountants, regulates the issuance of sub-reports only in cash.

But based on the regulation of the Central Bank of the Russian Federation “On the issue of payment cards” dated December 24, 2004 No. 266-P, we can conclude: organizations and individual entrepreneurs have the right to pay their expenses through a card issued to an individual authorized by them (clauses 1.5, 2.5). This position is confirmed by official explanations of the Ministry of Finance of the Russian Federation:

• letter dated July 21, 2017 No. 09-01-07/46781;
• letter dated August 25, 2014 No. 03-11-11/42288;
• letter dated October 5, 2012 No. 14-03-03/728.

Let's sum it up

• Registration of accountable money begins with an application from the accountable person or an order (instruction) from the employer.
• Based on this document, cash is issued from the cash desk or current account after the execution of payment documents (payment order or payment order).
• To report for spent accountable funds, the employee must collect supporting documents and fill out an advance report.
• If documents on accountable amounts are drawn up with errors or an advance report is not submitted, and the advance issued against the report is not returned, tax risks arise.

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