Exchange differences when conducting export-import transactions
All Russian organizations are required to keep accounting records in rubles. If they settle with the counterparty in foreign currency, then the transaction amount must be converted into rubles.
In general, recalculation should be made at the current exchange rate of the Central Bank of the Russian Federation. But if the contract specifies a different procedure for determining the exchange rate (currency clause), then the terms of the contract must be used (clause 5 of PBU 3/2006).
But transactions, especially export-import transactions, rarely take place in one day, so the exchange rate will change during the validity of the contract. This is one of the reasons for exchange rate differences.
If a company purchased goods from a foreign counterparty on a deferred payment basis, then on the delivery date the accountant must register it, reflecting the amount in rubles at the current Central Bank exchange rate.
But on the date of payment for the goods, the rate will most likely be different. Therefore, the company will pay the foreign supplier an amount different from the one at which the goods were registered.
If the exchange rate increases, a negative exchange rate difference arises - an additional expense. The company will need a larger amount in rubles for payment than the initial assessment of the goods. If the exchange rate decreases by the time of payment, the exchange rate difference will be positive - the company will save ruble funds.
In such cases, exchange rate differences in accounting should be reflected in account 91 “Other income and expenses”: negative - on debit, and positive - on credit.
Exchange rate and amount differences: income tax
The legal tender throughout the Russian Federation is the ruble, and organizations are required to account for assets and liabilities in this currency. If the exchange rate of a foreign currency against the ruble changes, exchange rate and amount differences may arise. We will talk about how exchange rate and amount differences are taken into account for profit tax purposes in this article.
Exchange differences
Often, when concluding agreements with counterparties, organizations set the contract price in foreign currency. This allows for Article 317 of the Civil Code of the Russian Federation, according to which a monetary obligation may stipulate that it is payable in rubles in an amount equivalent to a certain amount in foreign currency or conventional monetary units (ecus, special drawing rights, etc.). In this case, the amount payable in rubles is determined at the official exchange rate of the relevant currency or conventional monetary units on the day of payment, unless a different rate or another date for its determination is established by law or by agreement of the parties.
The use of foreign currency, as well as payment documents in foreign currency when making payments on the territory of the Russian Federation for obligations, is permitted in cases, in the manner and under the conditions specified by law.
For the purpose of taxing the profits of organizations, exchange rate differences are recognized as non-operating income (expenses).
Non-operating income in accordance with Article 250 of the Tax Code of the Russian Federation is recognized as:
- income in the form of a positive (negative) exchange rate difference resulting from the deviation of the sale (purchase) rate of foreign currency from the official rate established by the Central Bank of the Russian Federation on the date of transfer of ownership of foreign currency (clause 2 of Article 250 of the Tax Code of the Russian Federation);
- income in the form of positive exchange rate differences arising from the revaluation of property in the form of foreign currency values (except for securities denominated in foreign currency) and claims (liabilities), the value of which is expressed in foreign currency, including on foreign currency accounts in banks, carried out in connection with the change in the official exchange rate of foreign currency to the ruble of the Russian Federation, established by the Central Bank of the Russian Federation (clause 11 of article 250 of the Tax Code of the Russian Federation).
A positive exchange rate difference for profit tax purposes is an exchange rate difference that arises:
- when revaluing property in the form of foreign currency assets (with the exception of securities denominated in foreign currency);
- revaluation of claims denominated in foreign currency;
- discounting of liabilities denominated in foreign currency.
Non-operating expenses in accordance with subparagraph 5 of paragraph 1 of Article 265 of the Tax Code of the Russian Federation are expenses in the form of negative exchange rate differences arising from the revaluation of property in the form of foreign currency values (with the exception of securities denominated in foreign currency) and claims (liabilities), the value of which is expressed in foreign currency , including on foreign currency accounts in banks, carried out in connection with a change in the official exchange rate of foreign currency to the ruble of the Russian Federation, established by the Central Bank of the Russian Federation.
A negative exchange rate difference for the purpose of calculating income tax is an exchange rate difference arising from the depreciation of property in the form of currency values (except, as in the case of a positive exchange rate difference, securities denominated in foreign currency) and claims (liabilities), the value of which expressed in foreign currency, including for foreign currency accounts in banks, carried out in connection with changes in the official exchange rate of foreign currency against the ruble of the Russian Federation, established by the Central Bank of the Russian Federation.
The procedure for recalculating income and expenses, the value of which is expressed in foreign currency, depends on the method of recognition of income and expenses chosen by the organization and enshrined in the accounting policy.
As you know, the Tax Code of the Russian Federation provides for two methods of recognizing income and expenses - the accrual method and the cash method.
The procedure for determining income and expenses under the cash method is established by Article 273 of the Tax Code of the Russian Federation. According to paragraph 1 of this article, the date of receipt of income is recognized as the day of receipt of funds into bank accounts and (or) the cash desk, receipt of other property (work, services) and (or) property rights, as well as repayment of debt to the taxpayer in another way.
Expenses under the cash method in accordance with paragraph 2 of Article 273 of the Tax Code of the Russian Federation are recognized as expenses after their actual payment.
In other words, when using the cash method, income and expenses expressed in foreign currency are recalculated on the date of receipt and payment of funds.
The procedure for recognizing income and expenses when a taxpayer uses the accrual method is established by Articles 271 and 272 of the Tax Code of the Russian Federation, respectively.
Clause 8 of Article 271 of the Tax Code of the Russian Federation determines that income expressed in foreign currency for profit tax purposes is recalculated into rubles at the official rate established by the Central Bank of the Russian Federation on the date of recognition of the corresponding income. Obligations and claims expressed in foreign currency, property in the form of currency values are recalculated into rubles at the official exchange rate established by the Central Bank of the Russian Federation on the date of transfer of ownership of transactions with the said property, termination (fulfillment) of obligations and claims and (or) on the last day of the reporting period (tax) period, whichever occurred first.
The date of recognition of non-operating income on income in the form of a positive exchange rate difference on property and claims (liabilities), the value of which is expressed in foreign currency, is recognized as the last day of the current month, which is established by subclause 7 of clause 4 of Article 271 of the Tax Code of the Russian Federation.
A similar norm is established for the recognition of expenses. Expenses expressed in foreign currency, in accordance with paragraph 10 of Article 272 of the Tax Code of the Russian Federation, are recalculated into rubles at the official rate established by the Central Bank of the Russian Federation on the date of recognition of the corresponding expense. Obligations and claims expressed in foreign currency, property in the form of currency values are converted into rubles at the official rate established by the Central Bank of the Russian Federation on the date of transfer of ownership when carrying out transactions with such property, termination (fulfillment) of obligations and claims and (or) on the last date reporting (tax) period, depending on what happened earlier.
The date of recognition of non-operating expenses for expenses in the form of negative exchange rate differences on property and claims (liabilities), the value of which is expressed in foreign currency, is also recognized as the last day of the current month, which is determined by subparagraph 6 of paragraph 7 of Article 272 of the Tax Code of the Russian Federation.
How are exchange differences arising in connection with changes in the exchange rate of foreign currency against the ruble on funds received in foreign currency under a loan agreement taken into account for tax purposes?
Let us turn to the letter of the Ministry of Finance of Russia dated January 15, 2009 No. 03-03-06/1/17. It states that exchange rate differences (positive and negative) in connection with the revaluation of a debt obligation in the form of a loan received in foreign currency are taken into account for profit tax purposes by the Russian organization - the borrower on the date of termination (fulfillment) of the debt obligation to repay the loan, taking into account interest (provided for by the loan agreement) and (or) on the last day of the reporting (tax) period, depending on what happened earlier.
Exchange differences are also taken into account if the loan provided to the organization is interest-free, which is confirmed by the resolution of the Federal Antimonopoly Service of the Central District of November 30, 2006 No. A09-15467/05-21.
As follows from the case materials, the tax inspectorate conducted an audit of the taxpayer, as a result of which additional income tax was assessed to the taxpayer. The basis for additional tax assessment was the conclusion of the tax inspectorate that only interest accrued for the actual time of use of borrowed funds is recognized as income tax expenses. And since exchange rate differences arose in connection with the gratuitous use of someone else’s funds within the framework of borrowed legal relations, such expenses are associated with the gratuitous transfer of property (in this case, money) and, accordingly, should not be taken into account for tax purposes.
The court indicated that profit for Russian organizations, in accordance with paragraph 1 of Article 247 of the Tax Code of the Russian Federation, is recognized as income received, reduced by the amount of expenses incurred. Expenses are recognized as justified and documented expenses (losses) incurred (incurred) by the taxpayer.
Non-operating expenses not related to production and sales include, in particular, expenses in the form of negative exchange rate differences.
By virtue of paragraph 1 of Article 54 of the Tax Code of the Russian Federation, taxpayers-organizations calculate the tax base on the basis of data from accounting registers and (or) on the basis of other documented data on objects subject to taxation or related to taxation.
From the case materials it follows that the taxpayer entered into interest-free loan agreements, the purpose of which was to replenish working capital. Consequently, the loan received was used to finance the ongoing activities of the organization.
The organization carried out settlements in foreign currency, borrowed funds to its accounts were received from the lender also in foreign currency, which is confirmed by primary documents.
At the same time, the tax authority noted a violation by the taxpayer of paragraph 1 of Article 252 and subparagraph 5 of paragraph 1 of Article 265 of the Tax Code of the Russian Federation, which was expressed in overestimation of expenses in the form of a negative exchange rate difference when repaying the loan, due to economic unjustification.
The court indicated that the tax authority had not provided evidence of the economic unjustification of these expenses.
Taking into account these circumstances and taking into account the direct indication of the law on the possibility of taking these expenses into account when calculating income tax, the court decided that the tax inspectorate did not have legal grounds for assessing additional income tax to the taxpayer.
The procedure for accounting for tax purposes of exchange rate differences arising when making payments in foreign currency for production with a long technological cycle is discussed in the letter of the Ministry of Finance of Russia dated February 21, 2008 No. 03-03-06/1/118.
According to paragraph 3 of Article 248 of the Tax Code of the Russian Federation, income received by a taxpayer, the value of which is expressed in foreign currency, is taken into account in conjunction with income, the value of which is expressed in rubles. In this case, the recalculation of income in foreign currency is carried out by the taxpayer depending on the method of income recognition established in the accounting policy of the organization for tax purposes.
The procedure for recognizing income using the accrual method is established by Article 271 of the Tax Code of the Russian Federation. Based on paragraph 1 of this article, income is recognized in the reporting (tax) period in which it occurred, regardless of the actual receipt of funds, other property (work, services) and (or) property rights.
In this case, for income from sales, the date of receipt of income is recognized as the date of sale of goods (work, services, property rights), determined in accordance with paragraph 1 of Article 39 of the Tax Code of the Russian Federation, regardless of the actual receipt of funds (other property (work, services) and (or ) property rights) in payment for them.
The sale of goods, work or services in accordance with paragraph 1 of Article 39 of the Tax Code of the Russian Federation is recognized as the transfer on a reimbursable basis of ownership rights to goods (work, services).
Income expressed in foreign currency, as we have already said, for tax purposes is recalculated into rubles at the official rate established by the Central Bank of the Russian Federation on the date of recognition of the corresponding income, which is established by paragraph 8 of Article 271 of the Tax Code of the Russian Federation. Thus, the amount of income from sales received in foreign currency is determined on the date of transfer of ownership of the goods (work, services) being sold.
At the same time, paragraph 2 of Article 271 of the Tax Code of the Russian Federation determines that for production with a long (more than one tax period) technological cycle, if the terms of the concluded contracts do not provide for the phased delivery of work (services), income from the sale of these works (services) is distributed by the taxpayer independently in accordance with the principle of formation of expenses for the specified works (services).
As noted in the letter, organizations engaged in production with a long technological cycle, if they receive income in foreign currency within the framework of this production, initially recalculate them into rubles at the official rate established by the Central Bank of the Russian Federation on the date of their recognition.
Since the recognition of income received as part of production with a long technological cycle is carried out by the taxpayer solely for the purpose of taxation of profits and at the same time no debt arises under the agreement, then the recalculation of the amount of already calculated and recognized income, including those received in foreign currency, which arose in previous periods of income recognition within the framework of production with a long technological cycle is not performed.
Upon completion of production and after delivery of work (services) carried out within the framework of this technological cycle, the organization needs to determine the amount of income received, subject to accounting on the date of its recognition, at the rate established on the date of transfer of ownership of the results of the work. In this case, the amount of calculated income is reduced by amounts previously recognized for tax purposes on the basis of paragraph 3 of Article 248 of the Tax Code of the Russian Federation, as not subject to re-inclusion in income.
How is the concept of exchange rate difference defined in accounting? For accounting purposes, exchange rate differences mean the difference between the ruble valuation of an asset (liability), the value of which is expressed in foreign currency, on the date of fulfillment of the payment obligation or the reporting date of a given reporting period and the ruble valuation of the same asset (liability) on the date of its acceptance. accounting in the reporting period or the reporting date of the previous reporting period. This definition is contained in paragraph 3 of the Accounting Regulations “Accounting for assets and liabilities, the value of which is expressed in foreign currency” PBU 3/2006, approved by Order of the Ministry of Finance of Russia dated November 27, 2006 No. 154n.
Readers probably know that since the entry into force of PBU 3/2006, the concept of “amount differences” has ceased to exist in accounting. Differences that arise when the contract price is established in a foreign currency, but when paid in rubles, are also taken into account in accounting as exchange rate differences, while for profit tax purposes the concept of an amount difference exists.
Depending on the type of assets and liabilities, the value of which is expressed in foreign currency, in accounting, their value is recalculated on the date of the transaction, on the reporting date or on the date of change in the foreign currency exchange rate against the ruble.
For the purpose of calculating income tax, the recalculation of liabilities expressed in foreign currency, but payable in the currency of the Russian Federation, is carried out on the date of acceptance for accounting and on the date of repayment of the obligation; on the reporting date, the recalculation of liabilities is not carried out.
Thus, in accounting as of the reporting date, income or expenses will be recognized in the form of exchange rate differences, but not in tax accounting, since here the resulting amount difference will be taken into account in subsequent periods.
Due to the different procedures for recalculation between accounting and tax accounting, differences arise that lead to the need to apply the Accounting Regulations “Accounting for Income Tax Calculations” PBU 18/02, approved by Order of the Ministry of Finance of Russia dated November 19, 2002 No. 114n.
Amount differences
The Civil Code of the Russian Federation provides for the possibility of establishing the contract price in conventional monetary units. In particular, Article 317 of the Civil Code of the Russian Federation determines that a monetary obligation may stipulate that it is payable in rubles in an amount equivalent to a certain amount
in foreign currency or in conventional monetary units (ecus, special drawing rights, etc.). In this case, the amount payable in rubles is determined at the official exchange rate of the relevant currency or conventional monetary units on the day of payment, unless a different rate or another date for its determination is established by law or by agreement of the parties.
As you know, for profit tax purposes, in accordance with paragraph 1 of Article 248 of the Tax Code of the Russian Federation, income received by an organization is divided into income from sales and non-operating income.
Expenses by the amount of which income received is reduced when calculating the tax base for income tax, depending on their nature, conditions of implementation and direction of activity of the taxpayer, are divided into expenses associated with production and sales, and non-operating expenses, as established by paragraphs 1 and 2 Article 252 of the Tax Code of the Russian Federation.
Income in the form of the amount difference arising from the taxpayer, if the amount of obligations and claims incurred, calculated at the rate of conventional monetary units established by agreement of the parties on the date of sale (receipt) of goods (work, services), property rights, does not correspond to the actual amount received (paid) in rubles, according to clause 11.1 of Article 250 of the Tax Code of the Russian Federation are recognized as non-operating income.
Income received by taxpayers, the value of which is expressed in conventional units, on the basis of paragraph 3 of Article 248 of the Tax Code of the Russian Federation, is taken into account in conjunction with income, the value of which is expressed in rubles. Recalculation of income is carried out by the taxpayer depending on the method of income recognition chosen in the accounting policy for tax purposes.
In turn, expenses in the form of an amount difference that arose for the taxpayer under the same conditions, in accordance with subparagraph 5.1 of paragraph 1 of Article 265 of the Tax Code of the Russian Federation, are recognized as non-operating expenses.
Expenses incurred by the taxpayer, the cost of which is expressed in conventional units, in accordance with paragraph 5 of Article 252 of the Tax Code of the Russian Federation, are taken into account in conjunction with expenses, the cost of which is expressed in rubles. Recalculation of expenses is carried out by the taxpayer depending on the method of recognition of such expenses chosen in the accounting policy for tax purposes.
So, from the norms of the Tax Code of the Russian Federation it follows that the occurrence of an amount difference is possible only in the case when the cost of goods (work, services), property rights is determined by the parties to the agreement
in conventional monetary units, and payments under the agreement are made in rubles.
According to Article 316 of the Tax Code of the Russian Federation, which establishes the procedure for tax accounting of income from sales, if the price of the sold goods (works, services), property rights is expressed in conventional units, then the amount of proceeds from the sale is recalculated into rubles at the rate established by the Central Bank of the Russian Federation on the date of sale . The amount differences that arise in this case are taken into account either as part of non-operating income or as part of non-operating expenses.
The Tax Code of the Russian Federation, as you remember, provides for two methods of recognizing income and expenses - the accrual method and the cash method.
According to paragraph 5 of Article 273 of the Tax Code of the Russian Federation, for profit tax purposes, when using the cash method of recognizing income and expenses, amount differences are not taken into account.
Do not forget that not all organizations can determine the date of receipt of income (expenses) using the cash method, but only those whose amount of revenue from the sale of goods (work, services) excluding value added tax did not exceed 1,000,000 rubles . for every quarter.
The procedure for recognizing income and expenses when a taxpayer uses the accrual method is established by Articles 271 and 272 of the Tax Code of the Russian Federation, respectively.
The amount difference in accordance with paragraph 7 of Article 271 of the Tax Code of the Russian Federation is recognized as income:
- for the taxpayer-seller - on the date of repayment of receivables for sold goods (work, services), property rights, and in the case of advance payment - on the date of sale of goods (work, services), property rights;
- for the taxpayer-buyer - on the date of repayment of accounts payable for purchased goods (work, services), property, property or other rights, and in the case of advance payment - on the date of acquisition of the listed assets, property and rights.
The amount difference based on paragraph 9 of Article 272 of the Tax Code of the Russian Federation is recognized as an expense:
- for the taxpayer-seller - on the date of repayment of receivables for sold goods (work, services), property rights, and in the case of advance payment - on the date of sale of goods (work, services, property rights);
- for the taxpayer-buyer - on the date of repayment of accounts payable for purchased goods (work, services), property, property or other rights, and in the case of advance payment - on the date of acquisition of goods (work, services), property, property or other rights.
Letter No. 03-03-06/1/190 of the Ministry of Finance of Russia dated March 17, 2008 draws the attention of taxpayers to the fact that the Tax Code of the Russian Federation does not provide for the current revaluation of obligations (claims) expressed in conventional units. That is, it is not necessary to revaluate accounts receivable and payable, expressed in conventional units, at the reporting date and reflect the positive result of the revaluation as non-operating income, and the negative result as non-operating expenses for profit tax purposes.
When calculating the amount differences, taxpayers have many questions. It is not possible to consider all the issues related to accounting for amount differences within the framework of one article, so we will focus the readers’ attention on only some of them.
Amount differences arising when paying in advance
If the contract price of goods (works, services), property rights is determined in conventional units and the parties to the contract agree on the date on which the contract price is determined based on the exchange rate of the conventional unit, then amount differences arise only if the moment of acquisition (sale) falls on an earlier date than set by the parties to the contract for determining the price.
The letter of the Federal Tax Service of Russia dated May 20, 2005 No. 02-1-08/ [email protected] “On the procedure for accounting for tax purposes of amount differences” states that in cases where the contract price is determined by the parties in conventional units on the date of payment, the amount differences arise only for that part of the cost of goods (works, services, property rights) that turned out to be unpaid after obtaining ownership of the goods, property rights, results of work, services. As noted in the letter, when paying in advance, there are no differences in amounts.
A similar opinion was expressed in the letter of the Ministry of Finance of Russia dated September 4, 2008 No. 03-03-06/1/508, which noted that in the case of advance payment (full or partial) of the cost of goods for the paid cost of goods, income (expenses) in in the form of an amount difference, if payment is made in rubles, does not arise.
Specialists of the Ministry of Finance of Russia in letter dated April 24, 2008 No. 03-03-06/1/292 clarified that amount differences when making (receiving) advance payment for goods (work, services) in tax accounting do not arise regardless of who is the taxpayer's counterparty is a resident of the Russian Federation or a non-resident of the Russian Federation.
In letter No. 20-12/116284 of the Federal Tax Service of Russia for Moscow dated December 6, 2007, the issue of the procedure for accounting by the lessee of amount differences arising when paying these payments in rubles is considered. The letter states that in order to take into account the amount of differences in profit taxation, it is necessary to establish in the contract a date agreed upon by the parties on which the price of the lessor's services for providing the property for leasing to the lessee will be determined. Consequently, if the contract price is determined by the parties in conventional units on the date of payment, amount differences do not arise when pre-paying lease payments.
If the contract stipulates that the delivery of goods is made on the terms of full prepayment, and the transaction price is set at the time of shipment, then, according to specialists from the Federal Tax Service of Russia for Moscow, contained in letter dated June 29, 2007 No. 20-12/62182, it may an amount difference arises, which is determined on the date of sale (moment of shipment). If the transaction price is set on the day of preliminary (before the sale date) payment, no difference in amount arises, since the buyer’s receivables to the seller in the future (at the time of sale) are not subject to change.
In the letter of the Federal Tax Service of Russia for the city of Moscow dated June 28, 2007 No. 20-12/060981, the issue of the procedure for accounting for amount differences when purchasing an item of fixed assets is discussed in great detail in the case where, under the terms of the contract, payment is made as before the signing of the acceptance certificate , and after submitting documents for state registration of property rights.
If payment for an object is made in advance and in this case the ruble exchange rate established by the Central Bank of the Russian Federation on the date of payment is used for calculation, then the value of the object is formed before it is accepted for tax accounting under the transfer deed. Accordingly, there are no amount differences.
If the buyer makes a subsequent payment (after accepting the object under the acceptance certificate), then the value of the object for reflection in tax accounting is determined at the ruble exchange rate established by the Central Bank of the Russian Federation on the date of acceptance of the object. In this case, if the actually transferred amount deviates from the recorded value of the object on the date of its acceptance, a positive or negative amount difference may arise, which is included, respectively, in non-operating income or non-operating expense.
If the purchase and sale agreement for an object of fixed assets provides for a mixed form of payment in rubles at the rate of a conventional unit (advance payment and payment after transfer of the object), then the initial cost of the object will be formed based on the amount of the advance payment in rubles and the balance within the contractual value of the object in conventional units units, converted into rubles at the exchange rate on the date of adoption. Moreover, if the amount actually transferred (advance and final payment) deviates from the cost of the object according to tax accounting data, the amount differences may be reflected in tax accounting.
How to take into account the amount differences if the payment was made in different tax periods? To answer this question, we will give an example from judicial practice (resolution of the Federal Antimonopoly Service of the Moscow District dated November 5, 2008 No. KA-A40/10237-08).
During the tax audit, the tax authority established that an agreement in conventional units was concluded between the taxpayer and his counterparty. Payment under the agreement was made in three payments made in different tax periods. Since the amount actually paid under payment orders, upon full repayment of the obligation, exceeded the amount of the obligation under the agreement, the taxpayer had an amount difference taken into account as part of non-operating expenses.
Without disputing the fact that the difference arose, the tax authority considered that, in violation of paragraph 1 of Article 272 of the Tax Code of the Russian Federation, the taxpayer unreasonably included the amount difference in the expenses of the year in which the final payment was made, despite the fact that the expenses relate to the previous year, that is, to the year in which the business transaction was carried out.
Disagreeing with the opinion of the tax authority, the court proceeded from paragraph 9 of Article 272 of the Tax Code of the Russian Federation and the fact that before making the last payment it was impossible to determine the amount of the amount difference. The court reasonably took into account the essence of the amount difference, which is the difference between the cost of goods in rubles on the day of sale of the goods and on the day of full payment for the goods, due to changes in the exchange rate.
Amount differences on borrowed obligations The issue of the procedure for accounting for the difference arising in connection with a change in the exchange rate of a conventional unit against the ruble for funds received under a loan agreement in foreign currency is considered in the letter of the Federal Tax Service of Russia for Moscow dated July 7, 2008 No. 20-12/064118. In the letter, with reference to the provisions of paragraph 11.1 of Article 250 of the Tax Code of the Russian Federation and subparagraph 5.1 of paragraph 1 of Article 265 of the Tax Code of the Russian Federation, it is noted that in relation to credits (loans), the concept of “amount difference” does not apply.
If the amount of the loan returned in Russian rubles, calculated in conventional units, is less than the actual amount of the loan received, then the resulting difference is subject to accounting for non-operating income for profit tax purposes.
In the letter of the Federal Tax Service of Russia for Moscow dated April 9, 2007 No. 20-12/031924, the issue of the procedure for accounting by the lending organization for the amount differences arising when paying interest under a loan agreement concluded in US dollars was considered. The terms of the agreement stipulate that the loan is issued and repaid in rubles at the exchange rate of the Central Bank of the Russian Federation on the day of payment. As stated in the letter, the sale of goods, works or services, in accordance with subparagraph 1 of paragraph 3 of Article 39 of the Tax Code of the Russian Federation, does not include transactions related to the circulation of Russian and foreign currency.
Thus, the difference between the ruble estimate of the loan amount on the date the borrower received funds and the ruble estimate of the loan amount on the date of return of these funds to the lender does not fall within the definition of the amount difference.
When paying interest under loan agreements, the resulting amount differences between the ruble estimate of the interest amounts on the date of their accrual and the ruble estimate of the interest amounts on the date of their payment are taken into account by the lender as part of non-operating income (expenses) in the generally established manner.
Amount differences when selling securities
The issue of accounting for income (expenses) in the form of an amount difference by an organization selling securities (shares), the value of which is expressed in conventional monetary units, and payment for which is made in installments, is considered in the letter of the Ministry of Finance of Russia dated October 7, 2008 No. 03-03-06 /1/561.
According to the experts of the financial department, expressed in this letter, if the amount of the resulting demand for payment of transferred securities, expressed in conventional monetary units, does not correspond to the actual amount received in rubles, the organization has an amount difference taken into account in income (expenses) for profit tax purposes .
Example 1
Alpha LLC purchased goods from a foreign supplier in the amount of 1,000 euros with deferred payment. On the date of delivery, the euro exchange rate was 75 rubles, and on the date of payment – 78 rubles. Thus, the goods were registered at a cost of 75 x 1000 = 75,000 rubles, and when paying, the company spent 78 x 1000 = 78,000 rubles on the purchase of currency. A deviation of 3,000 rubles is a negative exchange rate difference.
DT 41 – KT 60 (RUB 75,000) – goods purchased and registered at the exchange rate on the date of purchase
DT 60 – CT 52 (RUB 78,000) – goods paid at the exchange rate on the date of payment
DT 91.2 – KT 60 (3000 rub.) – negative exchange rate difference
Exchange rate differences are determined similarly if the company itself supplies goods to foreign buyers with deferred payment. Sales proceeds must be determined at the Central Bank exchange rate on the date of shipment, and exchange rate differences must be calculated based on the exchange rate on the date of payment.
Example 2
Delta LLC sold goods worth $2,000 with deferred payment to a foreign buyer. On the date of shipment, the dollar exchange rate was 65 rubles, so the company took into account revenue in the amount of 65 x 2000 = 130,000 rubles. On the date of payment, the rate increased to 67 rubles per dollar and the ruble equivalent of the foreign exchange earnings received became equal to 67 x 2000 = 134,000 rubles. A deviation of 4,000 rubles is an additional income for the company, i.e. positive exchange rate difference.
DT 62 – CT 90 (RUB 130,000) – revenue accrued at the exchange rate on the date of shipment
DT 52 – CT 62 (RUB 134,000) – foreign currency earnings are credited to the account at the rate on the date of payment
DT 62 – KT 91.1 (4000 rub.) – positive exchange rate difference
If an organization received or issued an advance in foreign currency, then exchange rate differences do not arise (clause 7 of PBU 3/2006). In this case, revenue or costs are taken into account at the exchange rate on the date of receipt (issue) of the advance. Changes in the exchange rate by the time the advance payment is “closed” by shipment will not affect accounting in any way.
VAT from the seller for exchange rate differences in calculations in conventional units
When the exchange rate changes, there is no need to adjust the VAT that was previously charged on the advance payment or upon shipment.
If you had a shipment without prepayment, then determine the tax base and recalculate the cost of goods (work, services) from y. That is, in rubles you need it once - on the date of shipment. Recalculate the cost at the rate of the Bank of Russia, which was in effect on the date of shipment (clause 4 of Article 153 of the Tax Code of the Russian Federation).
There is no need to adjust the accrued VAT upon receipt of payment.
If, due to an increase in the exchange rate, the revenue on the day of payment is greater than the revenue that you calculated on the day of shipment, then a positive difference will arise. This difference, together with the VAT attributable to it, must be included in non-operating income for income tax (clause 4 of article 153, clause 11 of article 250 of the Tax Code of the Russian Federation).
If, on the contrary, the rate falls, there will be a negative difference. It, together with VAT, must be included in non-operating expenses (clause 4 of article 153, clause 5 of clause 1 of article 265 of the Tax Code of the Russian Federation).
An example of calculating the exchange rate difference from the seller when the buyer pays for the goods after shipment
The cost of the goods under the contract is 118,000 USD. e., including VAT at a rate of 18% - 18,000 USD. e. The conventional unit is equal to 1 US dollar.
On the date of shipment, the US dollar exchange rate according to the Bank of Russia is 70 rubles.
On the date of payment - 75 rubles.
- Let's calculate the cost of goods in rubles at the Bank of Russia exchange rate on the date of shipment:
118,000 USD e. x 70 rub. = RUB 8,260,000, including VAT - RUB 1,260,000.
That is, in the invoice for shipment, the seller will indicate the cost of the goods as 7,000,000 rubles. and accrued VAT at a rate of 18% - RUB 1,260,000.
- Let's calculate the cost of goods in rubles at the Bank of Russia exchange rate on the date of payment:
118,000 USD e. x 75 rub. = RUB 8,850,000, including VAT - RUB 1,350,000.
The seller does not issue an invoice for the new cost or the difference between the new and previous cost.
- Let's calculate the exchange rate difference. The dollar exchange rate on the date of payment has increased compared to the exchange rate on the date of shipment. This means there is a positive difference:
RUB 8,850,000 — 8,260,000 rub. = 590,000 rubles, including VAT - 90,000 rubles.
This difference is 590,000 rubles. the seller will include it in non-operating income.
If there was a 100% prepayment , then you determine the tax base twice - on the day of prepayment and on the day of shipment. But you recalculate the cost of goods (work, services) from y. That is, in rubles only once - on the day the prepayment is received. To recalculate, take the Bank of Russia exchange rate on the date of prepayment (clause 1, 14 of Article 167 of the Tax Code of the Russian Federation, Letter of the Federal Tax Service of Russia dated July 21, 2015 N ED-4-3/12813).
If on the date of shipment the exchange rate is y. e. will change, there is no need to recalculate the cost of goods (work, services). To determine the base, take their cost, which was on the date of prepayment. In the shipping invoice, also indicate the cost in rubles at the exchange rate on the date of receipt of the advance payment.
There will be no exchange rate differences in this situation.
In case of partial prepayment , determine the tax base twice: on the day of prepayment and on the day of shipment, and recalculate the cost of goods (work, services) from y. That is, in rubles you need this (clause 4 of article 153, clause 1, 14 of article 167 of the Tax Code of the Russian Federation, Letter of the Ministry of Finance of Russia dated December 23, 2015 N 03-07-11/75467):
- on the day of prepayment, recalculate from y. i.e. in rubles that part of the cost of goods (work, services) that was paid in advance. To recalculate, use the Bank of Russia exchange rate on the date of prepayment. In the future, do not recalculate this part of the cost;
- on the day of shipment, recalculate the remaining cost of goods (work, services) that was not paid in advance. For recalculation, take the Bank of Russia exchange rate on the date of shipment.
There is no need to recalculate the cost of goods (work, services) after shipment at the time when the remaining payment is received.
If, due to an increase in the exchange rate, the received revenue is greater than the revenue that you calculated on the day of shipment, then a positive difference will arise. This difference, together with the VAT attributable to it, must be included in non-operating income for income tax (clause 4 of article 153, clause 11 of article 250 of the Tax Code of the Russian Federation).
If, on the contrary, the rate falls, there will be a negative difference. It, together with VAT, will need to be included in non-operating expenses (clause 4 of Article 153, clause 5 of clause 1 of Article 265 of the Tax Code of the Russian Federation).
Example 3
Sigma LLC transferred an advance payment to a foreign counterparty for future delivery of goods in the amount of 5,000 euros. The exchange rate on the date of transfer of the advance payment is 80 rubles per euro. At the time of delivery, the euro exchange rate increased to 82 rubles, but the goods were registered at the rate on the date of payment, i.e. in the amount of 80 x 5,000 = 400,000 rubles.
If the advance received or paid covers part of the delivery cost, then the exchange rate difference must be calculated only for that part of the shipment (delivery) that is not covered by the advance payment.
Exchange differences when translating assets denominated in foreign currency
Exchange differences arise when recalculating the balances of foreign currency funds in the cash register and accounts of the organization, as well as securities (except for shares), if their value is determined in foreign currency.
In addition, it is necessary to recalculate current foreign currency settlement debts, except for debts on advances issued and received.
The organization is obliged to recalculate as of the reporting date, but has the right to determine exchange rate differences and more often as the exchange rate changes. Most organizations submit financial statements once a year, i.e. their reporting date will only be December 31st. But over the course of a year, exchange rates can change very significantly, and most of last year’s contracts will already be fulfilled.
On the other hand, it also makes no sense to recalculate debts and account balances every day at the slightest change in exchange rates. Therefore, businessmen usually choose a compromise option and calculate exchange rate differences on balances once a month. This procedure must be reflected in the accounting policies.
Example 5
An organization requires $5,000 to pay for imported goods. The dollar exchange rate set by the Central Bank on the date of purchase is 65 rubles, the bank rate is 67 rubles. Therefore, the organization will have a negative exchange rate difference in the amount of 5,000 x (67 – 65) = 10,000 rubles.
DT 57 – CT 51 (RUB 335,000) – the organization transferred money to purchase currency at the bank rate
DT 52 – CT 57 (325,000) – currency credited to the account at the Central Bank rate
DT 91.2 – KT 57 (10,000) – negative exchange rate difference
Example 6
In accordance with the constituent agreement, a foreign company must contribute 1,000 US dollars to the authorized capital of a Russian organization
On the date of signing the agreement, the dollar exchange rate was 72 rubles, and on the date of payment it became equal to 74 rubles
DT 75 – CT 80 (RUB 72,000) – the founder’s debt on the contribution to the capital company has been accrued
DT 52 – KT 75 (RUB 74,000) – the founder paid the deposit
DT 75 – CT 83 (RUB 2,000) – positive exchange rate difference attributed to additional capital
Exchange differences in tax accounting under the general tax system
Exchange differences for income tax must be taken into account according to the same principles as for accounting (clause 11, article 250, subclause 5, clause 1, article 265 of the Tax Code of the Russian Federation). Positive exchange rate differences in tax accounting are attributed to non-operating income, and negative ones - to non-operating expenses.
Exchange rate differences do not affect VAT. The VAT base is determined on the date of shipment or receipt of advance payment. Thus, the accrued VAT is “fixed” at the rate at which the goods were shipped or the advance was received. Any fluctuations in the exchange rate in the future will not be reflected in the calculation of VAT on this transaction.
Accounting for exchange rate and amount differences under a loan agreement in conventional units
Sometimes organizations prefer to enter into loan agreements not in rubles, but in conventional units tied to the US dollar or euro exchange rate. When exchange rates change, differences arise both in the principal amount of the loan and in interest. The reflection of these differences in accounting and tax accounting has its own characteristics.
In accordance with Art. 807 of the Civil Code of the Russian Federation, under a loan agreement, one party (the lender) transfers into the ownership of the other party (borrower) money or other things determined by generic characteristics, and the borrower undertakes to return to the lender the same amount of money (loan amount) or an equal number of other things received by him of the same kind and quality.
The monetary obligation must be expressed in rubles (Clause 1, Article 317 of the Civil Code of the Russian Federation). But it may be stipulated that it is payable in rubles in an amount equivalent to a certain amount in foreign currency or in conventional monetary units (Clause 2 of Article 317 of the Civil Code of the Russian Federation). A monetary obligation expressed in foreign currency, if such obligation according to the contract or based on the essence of the transaction is payable in Russian rubles, should be considered as an obligation expressed in conventional units.
Reflection of differences in the borrower's accounting
Accounting.
The principal amount of the obligation for a loan received by an organization for a period of no more than 12 months is reflected in accounts payable on account 66 “Settlements for short-term loans and borrowings” (clause 2 of PBU 15/2008 “Accounting for expenses on loans and credits”, Instructions for application of the Chart of Accounts).
According to clauses 1, 4-7 of PBU 3/2006 “Accounting for assets and liabilities, the value of which is expressed in foreign currency,” the recalculation into rubles of debt to the lender for the principal amount of the debt is carried out on the date of receipt of funds, reporting dates and the date of repayment of the loan. As a result of such recalculation, due to changes in the dollar exchange rate in accounting, positive (negative) exchange rate differences arise, which are taken into account as part of other income (expenses) (clause 3, 11, 12, 13 PBU 3/2006, clause 7 PBU 9 /99 “Income of the organization” and clause 11 of PBU 10/99 “Expenses of the organization”).
Interest payable to the lender is reflected in accounting separately from the principal amount of the obligation for the loan received (clauses 3 and 4 of PBU 15/2008, Instructions for using the Chart of Accounts).
Tax accounting.
In tax accounting, funds received (returned) under a loan agreement are not taken into account when determining the tax base for income tax as part of income (expenses) (subclause 10, clause 1, article 251 and clause 12, article 270 of the Tax Code of the Russian Federation).
When using the accrual method in tax accounting in accordance with clause 11.1 of Art. 250 and similar 5.1 clause 1 art. 265 of the Tax Code of the Russian Federation, when an organization sells goods (work, services, property rights), the cost of which is expressed in conventional units, amount differences arise. The Tax Code of the Russian Federation does not directly mention the recognition as income and expenses of any other amount differences on obligations expressed in conventional units.
At the same time, the Ministry of Finance of Russia (letter dated April 2, 2009 No. 03-03-06/1/204) believes that from para. 4 paragraphs 1 art. 269 of the Tax Code of the Russian Federation it follows that amount differences can also arise on debt obligations denominated in foreign currency and payable in rubles. According to the Russian Ministry of Finance, the amount difference on a debt obligation is the difference between the amount of funds issued to the borrower and the amount actually returned to them. The date of recognition of this difference is the date the borrower fulfills the debt obligation (since it is impossible to calculate the amount of the difference before this date). This conclusion is consistent with the norms of subsection. 2 clause 7 art. 271 and para. 3 clause 9 art. 272 of the Tax Code of the Russian Federation.
In letter No. 03-03-06/1/348 of the Ministry of Finance of Russia dated May 27, 2009, it is explained that the borrower’s negative difference in the principal amount of the loan must be normalized. The financial department considers the negative difference as a fee for using the loan, which must be taken into account as interest under Art. 269 of the Tax Code of the Russian Federation.
Nevertheless, there is a court decision (resolution of the Seventeenth Arbitration Court of Appeal dated September 18, 2006 No. 17AP-301/06AK), in which the arbitrators come to the conclusion that the resulting negative amount difference cannot be:
— qualify as a fee for using a loan;
- equate for tax purposes to interest and take into account in accordance with Art. 269 of the Tax Code of the Russian Federation.
Since there is no clear answer to this question in the current legislation, the borrower must independently decide whether to normalize the negative difference in the principal amount of the debt or not.
Interest accrued under the loan agreement is included in non-operating expenses. Basis - sub. 2 p. 1 art. 265 Tax Code of the Russian Federation.
The dates for recognizing these expenses using the accrual method are the last date of the corresponding reporting period and the date of termination of the agreement (clause 8 of Article 272 of the Tax Code of the Russian Federation).
Based on the clarifications of the Ministry of Finance of Russia (letters dated 03/02/2006 No. 03-03-04/2/51 and dated 03/13/2006 No. 03-03-04/2/66), the difference between the amounts of accrued and paid interest is recognized as a total and is taken into account in generally established procedure (the same is true for the lender).
In accordance with paragraph 1 of Art. 269 of the Tax Code of the Russian Federation in the absence of debt obligations to Russian organizations issued in the same quarter on comparable terms, as well as at the choice of the taxpayer, the maximum amount of interest recognized as an expense (including interest and amount differences on obligations expressed in conventional monetary units as established by agreement of the parties exchange rate of conventional monetary units), when issuing a debt obligation in rubles, is taken equal to the refinancing rate of the Bank of Russia, increased by 1.1 times (from September 1, 2008 to July 31, 2009 - by 1.5 times, from August 1, 2009 until December 31, 2009 - 2 times).
The refinancing rate of the Central Bank of the Russian Federation is understood (clause 1 of Article 269 of the Tax Code of the Russian Federation):
- in relation to debt obligations that do not contain a condition on changing the interest rate during the entire term of the debt obligation - the rate in effect on the date of raising funds;
- in relation to other debt obligations - the refinancing rate effective on the date of recognition of expenses in the form of interest.
Due to differences in accounting and tax accounting in accordance with the requirements of the Accounting Regulations “Accounting for calculations of corporate income tax” (PBU 18/02), approved by Order of the Ministry of Finance of Russia dated November 19, 2002 No. 114n, permanent differences arise in the organization’s accounting.
Let's look at an example of the procedure for reflecting differences in the principal amount of debt and interest in the borrower's accounting.
Example 1
- The organization received a loan in an amount equivalent to $31,250 on January 15, 2009. The taxpayer is under the general taxation regime, uses the accrual method of tax accounting and calculates monthly advance payments based on the actual profit received. The organization has no other debt obligations. Interest at the rate of 30% per annum is paid on the date of repayment of the principal amount - April 10, 2009. There is no provision for changes in the interest rate during the entire term of the agreement.
The refinancing rate on the date of raising funds is set by the Central Bank of the Russian Federation at 13%. The dollar to ruble exchange rate is set by the Central Bank of the Russian Federation (conditionally):
January 15, 2009 - 32 rubles/dollar. USA;
January 31, 2009 - 35.41 rubles/dollar. USA;
February 28, 2009 - 35.72 rubles/dollar. USA;
March 31, 2009 - 34.01 rub./dollar. USA;
April 10, 2009 (date of payment of interest and repayment of principal) - 33.53 rubles/dollar. USA.
Let's calculate the amount of interest (Tables 1 and 2).
Table 1
Amount of interest in accounting
date | Amount of interest, rub. |
31.01 | 14552.06 ($31,250 x 30%: 365 days x 16 days x 35.41 rubles) |
28.02 | 25689.04 ($31,250 x 30%: 365 days x 28 days x 35.72 rubles) |
31.03 | 27079.88 ($31,250 x 30%: 365 days x 31 days x 34.01 rubles) |
10.04 | 8612.15 ($31,250 x 30%: 365 days x 10 days x RUB 33.53) |
Total | 75933.13 (RUB 14552.06 + RUB 25689.04 + RUB 27079.88 + RUB 8612.15) |
table 2
The amount of interest taken into account in reducing the tax base for income tax
date | Amount of interest, rub. |
31.01 | 9458.84 ($31,250 x 13% x 1.5: 365 days x 16 days x 35.41 rubles) |
28.02 | 16697.88 ($31,250 x 13% x 1.5: 365 days x 28 days x 35.72 rubles) |
31.03 | 17601.92 ($31,250 x 13% x 1.5: 365 days x 31 days x 34.01 rubles) |
10.04 | 5597.90 ($31,250 x 13% x 1.5: 365 days x 10 days x 33.53 rubles) |
Total | 49356.54 (9458.84 dollars + 16697.88 rubles + 17601.92 rubles + 5597.90 rubles) |
The difference in percentage according to accounting and tax accounting data leads to the formation of permanent differences and, accordingly, permanent tax liabilities (PNO). Their values are given in table. 3.
Table 3
PNO value by percentage
date | Difference between accounting and tax accounting data, rub. | PNO (gr. 2 x 20%), rub. |
31.01 | 5093,22 (4552,06 – 9458,84) | 1018,64 |
28.02 | 8991,16 (25689,04 – 16697,88) | 1798,23 |
31.03 | 9477,96 (27079,88 – 17601,92) | 1895,60 |
10.04 | 3014,25 (8612,15 – 5597,90) | 602,85 |
The exchange rate difference in accounting for the principal amount of debt and, accordingly, permanent tax assets (PTA) and permanent tax liabilities are given in table. 4.
Table 4
Exchange rate difference, PNA value (PNA) on the principal amount of debt
date | Exchange rate difference on the principal amount of debt, rub. | PNA or PNO, rub. (gr. 2 x 20%) |
31.01 | 106562.50 [(35.41 – 32.00) x 31,250] | 2112.50 (PNO) |
28.02 | 9687.50 [(35.72 – 35.41) x 31,250] | 1937.50 (PNO) |
31.03 | –53437.50 [(34.01 – 35.72) x 31,250] | 10687.50 (PNA) |
10.04 | –15000 [(33.53 – 34.01) x 31,250] | 3000 (PNA) |
In accordance with the Instructions for using the Chart of Accounts, the following entries are reflected in the borrower’s accounting records (Table 5).
Table 5
Reflection of transactions in the borrower's accounting records
date | Debit | Credit | Amount, rub. | Contents of operation |
15.01 | 51 | 66-1 | 1 000 000 | The amount of the loan received is reflected (32 rubles x $31,250) |
31.01 | 91-2 | 66-1 | 106562,50 | Exchange rate difference on the principal amount of debt |
99 | 68 | 21312,50 | Reflected PNO (principal amount of debt) | |
91-2 | 66-2 | 14552,06 | Interest accrued for January | |
99 | 68 | 1018,64 | Reflected PNO (percentage) | |
28.02 | 91-2 | 66-1 | 9687,50 | Exchange rate difference on the principal amount of debt |
99 | 68 | 1937,50 | Reflected PNO (principal amount of debt) | |
91-2 | 66-2 | 127,40 | Exchange rate difference on interest accrued for January [(35.72 rubles - 35.41 rubles) x $31,250 x 30%: : 365 days. x 16 days] | |
99 | 68 | 25,48 | Reflected PNO | |
91-2 | 66-2 | 25689,04 | Interest accrued for February | |
99 | 68 | 1798,23 | Reflected PNO (percentage) | |
31.03 | 66-1 | 91-1 | 53437,50 | Exchange rate difference on the principal amount of debt |
68 | 99 | 10687,50 | Reflected PNA (principal amount of debt) | |
66-2 | 91-1 | 1932,52 | Exchange rate difference on interest accrued for January, February [(RUB 34.01 – RUB 35.72) x $31,250 x x 30%: 365 days. x (16 days + 28 days)] | |
68 | 99 | 386,50 | PNA reflected | |
91-2 | 66-2 | 27079,88 | Interest accrued for March | |
99 | 68 | 1895,60 | Reflected PNO (percentage) | |
10.04.2009 | 66.1 | 91.1 | 15 000 | Exchange rate difference on the principal amount of debt |
68 | 99 | 3000 | Reflected PNA (principal amount of debt) | |
66.1 | 51 | 1047812,50 | The principal amount of the debt was returned | |
66.2 | 91.1 | 924,66 | Exchange rate difference on interest accrued for January - March [(33.53 - 34.01) x 31,250 x 30%: 365 days. x (16 days + 28 days + 31 days)] | |
68 | 99 | 184,93 | PNA reflected | |
91.2 | 66.2 | 8612,16 | Interest accrued for April | |
99 | 68 | 602,85 | Reflected PNO (percentage) | |
66.2 | 51 | 73203,34 | Interest paid |
Reflection of differences in lender accounting
Accounting.
In accounting, loans provided to other organizations that provide for the payment of interest are reflected as financial investments (clauses 2, 3 of PBU 19/02 “Accounting for financial investments”). The cost of financial investments expressed in foreign currency, for reflection in accounting and financial statements, is subject to conversion into rubles at the rate valid on the date of the loan (clauses 1, 4-6 PBU 3/2006). Subsequently, it is recalculated into rubles on the reporting date and on the loan repayment date (clause 7 of PBU 3/2006).
Interest to be received by the organization under the loan agreement is recognized as part of other income on the last day of the reporting period (clause 7, 10.1, 16 of PBU 9/99). The borrower's interest payment debt is recalculated into rubles on the date of its occurrence (date of accrual of interest) and the date of its repayment (date of payment by the borrower of interest) (clause 7 of PBU 3/2006).
Tax accounting.
According to para. 1 tbsp. 250 of the Tax Code of the Russian Federation, a positive amount difference between the returned and issued loan amounts is recognized as non-operating income.
If the exchange rate depreciates, then the amount to be received from the borrower in rubles will be less than the amount of the loan issued to him. Consequently, the lender has a negative amount difference. According to the Russian Ministry of Finance, such a difference is not taken into account when calculating income tax (see letters from the Russian Ministry of Finance dated October 6, 2005 No. 03-03-04/1/251 and dated May 14, 2005 No. 03-03-01-04/1/ 256).
Example 2
- Let's use the conditions of example 1 and continue with it. Let's assume that the lender is under the general taxation regime, uses the accrual method of tax accounting and calculates monthly advance payments based on the actual profit received.
In accordance with the Instructions for using the Chart of Accounts, the following entries are reflected in the lender's accounting (Table 6).
In tax accounting, the amount difference on the date of repayment of the debt on the principal amount of the debt will be 47,812.50 rubles. [$31,250 x (RUB 33.53 – RUB 32)].
Since the exchange rate of the US dollar against the ruble has increased, the lender's positive amount of the principal amount of the debt will increase the tax base for income tax.
Accrued interest is included in the lender's income. The total difference in interest is -2729.79 rubles. (RUB 73,203.34 – RUB 75,933.13).
This difference will reduce the tax base for income tax.
Table 6
Reflection of transactions in the lender's accounting
date | Debit | Credit | Amount, rub. | Contents of operation |
15.01 | 58.3 | 51 | 1 000 000 | Funds were transferred under the loan agreement (RUB 32 x USD 31,250) |
31.01 | 58-3 | 91-1 | 106562,50 | Exchange rate difference on the principal amount of debt |
68 | 99 | 21312,50 | Reflected PNA (principal amount of debt) | |
76 | 91-1 | 1452,06 | Interest accrued for January | |
28.02 | 58-3 | 91-1 | 9687,50 | Exchange rate difference on the principal amount of debt |
68 | 99 | 1937,50 | Reflected PNA (principal amount of debt) | |
76 | 91-1 | 127,40 | Exchange rate difference on interest accrued for January [(35.72 rubles - 35.41 rubles) x $31,250 x 30%: 365 days. x 16 days] | |
68 | 99 | 25,48 | PNA reflected | |
76 | 91-1 | 25689,04 | Interest accrued for February | |
31.03 | 91-2 | 58-3 | 53437,50 | Exchange rate difference on the principal amount of debt |
99 | 68 | 10687,50 | Reflected PNO (principal amount of debt) | |
91-2 | 76 | 1932,52 | Exchange rate difference on interest accrued for January, February [(RUB 34.01 – RUB 35.72) x USD 31,250 x 30%: 365 days. x (16 days + 28 days)] | |
99 | 68 | 386,50 | Reflected PNO | |
76 | 91-1 | 27079,88 | Interest accrued for March | |
10.04 | 91-2 | 58-3 | 15 000 | Exchange rate difference on the principal amount of debt |
99 | 68 | 3000 | Reflected PNO (principal amount of debt) | |
51 | 58-3 | 1047812,50 | The principal amount of the debt was returned | |
91-2 | 76 | 924,66 | Exchange rate difference on interest accrued for January - March [(RUB 33.53 - - RUB 34.01) x $31,250 x 30%: 365 days. x (16 days + 28 days + 31 days)] | |
99 | 68 | 184,93 | Reflected PNO | |
76 | 91-1 | 8612,16 | Interest accrued for April | |
51 | 76 | 73203,34 | Interest payment received from the borrower |
Exchange rate differences under the simplified tax system
When using the simplified tax system, there is no need to revaluate assets and liabilities expressed in foreign currency (clause 5 of article 346.17 of the Tax Code of the Russian Federation). It turns out that in general, exchange rate differences do not affect the calculation of the “simplified” tax.
But there is one exception here. If a businessman experiences a positive exchange rate difference when selling or buying foreign currency, he must take this income into account when calculating the simplified tax system. Moreover, the “simplified” cannot take into account the negative exchange rate difference in a similar situation. The Ministry of Finance indicated this in a letter dated January 15, 2020 No. 03-11-11/1310 .
The fact is that exchange rate differences when buying and selling currency do not relate to the revaluation of assets and liabilities. For income tax they must be taken into account in accordance with paragraph 2 of Art. 250 Tax Code of the Russian Federation. And the “simplified” ones must take into account non-operating income according to the requirements of Art. 250 Tax Code of the Russian Federation. This is indicated in paragraph 1 of Art. 346.15 Tax Code of the Russian Federation.
On the other hand, in the closed list of expenses for the simplified tax system (Article 346.17 of the Tax Code of the Russian Federation) there are no negative exchange rate differences. This means that they cannot be taken into account in any case.
Therefore, “simplified traders” who buy or sell currency are at a disadvantage compared to companies on OSNO.
Accounting and taxation of exchange rate differences
Alina Margutova
November 26, 2021 657
Business
Exchange rate differences arise when exchange rates fluctuate if an organization is engaged in imports or exports, and all transactions are carried out in foreign currency. Let's talk about how to reflect exchange rate differences in accounting and tax accounting.
Types of exchange rate differences
The exchange rate difference depends on how the exchange rate has changed: if it has increased, then a positive difference is formed, if it has fallen, a negative difference will be formed.
With accounts receivable, a positive exchange rate difference is the organization’s income, because the debtor will pay more than the original amount, and a negative difference is an expense. If the company itself is a debtor, then the opposite is true for it.
Accounting for exchange rate differences
The exchange rate difference is taken into account as part of other income and expenses on account 91 “Other income and expenses”. The exception is settlements with the founders: in this case, exchange rate differences are charged to account 83 “Additional capital”.
A positive exchange rate difference is reflected in account 91.01 for accounts receivable or on account 91.02 for accounts payable.
Negative exchange rate differences are reflected in account 91.02 for accounts receivable and in account 91.01 for accounts payable.
When taking into account exchange rate differences, the following types of postings are made.
Exchange differences and foreign currency account
As the Central Bank exchange rate increases, the ruble equivalent of foreign currency increases. In this case, you need to recognize other income:
- Debit of account 52 “Currency accounts”—Credit of account 91, subaccount “Other expenses”.
- Debit account 91, subaccount “Other expenses” - Credit account 52.
- Debit account 91, subaccount “Other expenses” - Credit account 50 “Cash”;
- Debit of account 50 - Credit of account 91, subaccount “Other income”.
When the exchange rate of the Central Bank decreases, another expense arises, which is reflected in the opposite entry:
Exchange differences in foreign currency at the organization's cash desk are reflected according to the same principle:
Exchange differences when purchasing non-current assets and inventories
The cost of fixed assets, intangible assets and inventories is fixed at the exchange rate of the Central Bank of the Russian Federation on the date of their acceptance for accounting and does not change anymore. Only the outstanding payment to the supplier can be revalued. As a result, positive or negative exchange rate differences arise, which are reflected in the following transactions:
- Debit of account 91 “Other income and expenses”, subaccount “Other expenses” Credit of account 60 “Settlements with suppliers and contractors” - Negative exchange rate difference on settlements with suppliers is reflected;
- Debit of account 60 “Settlements with suppliers and contractors” Credit of account 91 “Other income and expenses”, subaccount “Other income” - Reflects the positive exchange rate difference in settlements with the supplier.
Advances and exchange differences
The amounts of advances received and issued are accounted for at the exchange rate on the date of receipt or transfer of funds, respectively, and are not revalued.
Exchange rate differences when buying and selling currencies
When purchasing currency, the following transactions are required:
Account Dt | Kt account | Contents of operation | Primary document |
57 | 52 | Transferred funds for the purchase of currency | Bank statement for ruble account |
52 | 57 | After conversion, the currency arrived at the company’s account | Bank statement for foreign currency account |
57 | 91.01 | Positive exchange rate difference reflected | Accounting certificate-calculation |
91.02 | 57 | Negative exchange rate difference reflected | Accounting certificate-calculation |
When selling currency, the following transactions are made:
Account Dt | Kt account | Contents of operation | Primary document |
57 | 52 | Selling currency for conversion | Bank statement for foreign currency account |
52 | 57 | Ruble funds received after conversion | Bank statement for ruble account |
57 | 91.01 | Positive exchange rate difference reflected | Accounting certificate-calculation |
91.02 | 57 | Negative exchange rate difference reflected | Accounting certificate-calculation |
Tax accounting of exchange rate differences
VAT
VAT is not calculated on exchange rate differences. The tax base for VAT is determined on the day of shipment of goods, performance of work, provision of services or transfer of property rights, and on the same date the currency is converted into rubles.
Income tax
Taxpayers are required to revaluate currency values. Accounting for exchange rate differences depends on their type and accounting method. Accounting methods and the procedure for their application must be enshrined in the accounting policy.
The positive exchange rate difference arising during revaluation is the organization’s income. It is included in non-operating income.
Under the accrual method, income is recognized on the date when one of the following events occurs first:
- transfer of ownership of currency during transactions with foreign currency;
- the last day of the month has arrived;
- termination or fulfillment of a foreign currency obligation and claim if the date does not coincide with the last day of the month.
With the cash method, exchange rate differences do not arise because the amount of foreign currency debt coincides with the amount that was transferred to the counterparty.
When revaluing currency values in accounts, you can use the same method as with the accrual method.
The following positive exchange rate differences cannot be recognized as income:
- For securities denominated in foreign currency.
- For advances issued and received. But in case of termination of the transaction, you will have to recalculate the obligation to return the money from the date of receipt of the advance until the day of termination of the contract. The resulting positive exchange rate difference must be included in non-operating income, and the negative exchange rate difference must be included in expenses.
- If you received a currency that is not taken into account in the tax base - targeted funds in foreign currency or a contribution to the authorized capital.
The negative difference is taken into account in the organization's expenses.
Under the accrual method, expenses are recognized on the date of the earliest event:
- transfer of ownership of currency when performing transactions with currency;
- on the last day of each month;
- on the date of termination or fulfillment of currency obligations and claims.
Under the cash method, there are no exchange differences, except for the currency in the accounts. In this case, you can determine the date of recognition of expenses in the same way as with the accrual method.
It is impossible to take into account the negative differences that arose in expenses:
- for securities in foreign currency, advances and for currency that is not taken into account in the tax base;
- for obligations and claims not related to activities aimed at generating income.
When buying and selling currencies, there may also be income or expense.
Purchasing a currency below the Central Bank rate is non-operating income, above it is non-operating income. When selling, on the contrary, an expense arises if the exchange rate is lower than the Central Bank, and if it is higher, an income occurs.
Under the accrual method, the difference must be recognized on the date of transfer of ownership of the currency.
Under the cash method, income is taken into account on the date of receipt of currency or rubles into the organization’s account.
simplified tax system
Simplified people do not revaluate currency values and liabilities for tax accounting, so no difference arises.
The exception is the sale or purchase of currency: if a positive difference arises, it must be taken into account in non-operating income and tax must be paid. It is impossible to take into account the negative difference in costs, because The simplified list of expenses is closed.
UTII
From January 1, 2021, UTII will cease to operate. But before that, it should be taken into account that if a company only conducts activities on UTII, the exchange rate does not affect the amount of its tax.
Alina Margutova
November 26, 2021 657
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Exchange differences with unified agricultural tax, UTII and PSN
The procedure for recognizing income and expenses under the unified agricultural tax is in many ways similar to the simplified tax system. It also does not take into account the revaluation of foreign currency assets and liabilities (clause 5.1 of Article 346.5 of the Tax Code of the Russian Federation), and income in general must be recognized according to the standards established for income tax (clause 1 of Article 346.5 of the Tax Code of the Russian Federation). The list of expenses under the Unified Agricultural Tax, as well as under the simplified tax system, is closed (clause 2 of Article 346.5 of the Tax Code of the Russian Federation).
Therefore, we can conclude that the procedure discussed above for accounting for exchange rate differences during “simplified” applies to the Unified Agricultural Tax, although there is no separate explanation from tax authorities on this topic yet.
With UTII and PSN, the tax does not depend on income and expenses, so exchange rate differences do not affect tax accounting in any way.
However, under the patent system, it is necessary to take into account income to determine the annual limit of 60 million rubles. after exceeding which the taxpayer is deprived of the right to use the PSN. According to the Ministry of Finance, exchange rate differences do not need to be included in revenue to determine the specified limit (letter dated May 25, 2016 No. 03-11-12/30538 ).
Exchange rate differences and interest on loans
EXAMPLE 1
Brigantina LLC is building a business center under contract. To finance the investment project, a loan agreement was concluded to provide an amount equivalent to $1 million at 20 percent per annum. On August 3, 2009, money (rubles) arrived in the organization’s bank account. Interest is calculated by the bank monthly - on the last day of the month at the official rate. For August, their amount was $15,342.47 (USD 1,000,000: 365 days x 28 days x 20%).
They were paid on September 8, 2009.
In accordance with the agreement, interest is paid at the official exchange rate of the Central Bank of the Russian Federation on the day of payment. The dollar exchange rate as of August 3, 2009 was 31.1533 rubles. per US dollar, as of August 31, 2009 - 31.5687 rubles. per US dollar, as of September 8, 2009 - 31.4298 rubles. per US dollar.
The accountant of Brigantina LLC reflected the transactions related to the accounting of the loan received as follows.
August 3, 2009:
DEBIT 51 CREDIT 67 subaccount “Principal Debt”
- RUB 31,153,300. (31.1533 rubles x 1,000,000 USD) - a loan was received (reflected in rubles and foreign currency).
August 31, 2009:
DEBIT 91 subaccount “Other expenses” CREDIT 67 subaccount “Principal debt”
- 415,400 rubles. ((31.5687 rub/USD - 31.1533 rub/USD) x 1,000,000 USD) - reflects the exchange rate difference on the principal debt (increase in debt due to an increase in the exchange rate);
DEBIT 08 CREDIT 67 subaccount “Interest”
— 484,341.83 rub. (USD 15,342.47 x RUB 31.5687/USD)—interest accrued for August (shown in rubles and foreign currency).
September 8, 2009:
DEBIT 67 subaccount “Interest” CREDIT 51
— 482,210.76 rub. (USD 15,342.47 x RUB 31.4298/USD) — interest paid (shown in rubles and foreign currency);
DEBIT 67 subaccount “Interest” CREDIT 91
— 2131.07 rub. ((15,342.47 USD x (31.5687 rub/USD - 31.4298 rub/USD)) - reflects the exchange rate difference on interest obligations. Tax accounting Let's consider how costs associated with the use of borrowed funds are taken into account when taxing profits. " INTEREST" LOSSES First of all, let us recall that in tax accounting expenses on debt obligations are reflected taking into account the restrictions established by Article 269 of the Tax Code of the Russian Federation. At the same time, we note that loans expressed in conventional units are recognized as debt obligations issued in rubles. Therefore, according to the currency criterion they are comparable to loans denominated in rubles (letter of the Ministry of Finance of Russia dated July 30, 2009 No. 03-03-06/1/499).
For tax purposes, the borrower recognizes interest as non-operating expenses, regardless of the investment nature of the loan. This follows from the provisions of subparagraph 2 of paragraph 1 of Article 265 of the Tax Code of the Russian Federation.
Non-operating expenses must be recognized as expenses of the current period (clause 2 of Article 318 of the Tax Code of the Russian Federation). Moreover, if the duration of the contract falls on more than one reporting period, the expense is recognized as incurred and is included in the corresponding expenses at the end of the reporting period.
In the event of termination of the agreement (repayment of the debt obligation) before the expiration of the reporting period, the expense is recognized on the date of termination of the agreement or repayment of the debt obligation. This is provided for in paragraph 8 of Article 272 of the Tax Code of the Russian Federation.
Consequently, interest on loans cannot be included in the initial cost of the construction project. Such clarifications are contained in letters of the Ministry of Finance of Russia dated June 18, 2009 No. 03-03-06/1/408 and dated February 3, 2009 No. 03-03-06/1/37.
And if the company does not have sufficient income during the construction period, it will have to submit “unprofitable” income tax returns to the tax office.
Is it possible to avoid unwanted reflection of these losses in the declaration?
Let us turn to paragraph 1 of Article 252 of the Tax Code of the Russian Federation. It states that expenses are recognized as expenses provided that they are incurred to carry out activities aimed at generating income. Meanwhile, during the construction of the facility for their own needs, activities directly aimed at generating income have not yet begun. For the reason that there is no object that allows you to generate income. But the All-Russian Classifier of Types of Economic Activities OK 029-2007* (NACE Rev. 1.1) connects the concept of economic activity with the production process. The activity is characterized by production costs, the production process and the output of products (provision of services). All these signs are absent in the situation under consideration. In addition, during a crisis, construction at any stage may be frozen.
Conclusion
Exchange rate differences in accounting arise in the following cases:
- Changes in the foreign currency exchange rate during the execution of the transaction.
- Translation of assets and liabilities denominated in foreign currencies, excluding shares and advances.
- Buying or selling foreign currency at a rate different from the Central Bank rate.
To calculate income tax, exchange rate differences are taken into account according to the same rules as in accounting. Exchange rate differences do not affect the calculation of VAT.
For the simplified taxation system and unified agricultural tax, it is necessary to take into account only income in the form of positive exchange rate differences that arose during the purchase and sale of currency.
When calculating UTII and the cost of a patent, exchange rate differences are not used.
Classification of exchange rate differences
Exchange differences as an element of income and expenses taken into account when calculating income tax can arise as a result of financial and economic transactions, which can be generally divided into two groups:
- exchange rate differences arising when the taxpayer receives foreign currency as payment for the fulfillment by the taxpayer's counterparties of obligations to purchase goods (works, services);
- exchange rate differences arising as a result of revaluation of assets and liabilities of the taxpayer in connection with changes in the official ruble exchange rate, if they are not related to payments for goods (work, services) sold.
Of course, the conclusion about the impossibility of generating income and expenses in the form of exchange rate differences for a taxpayer using the cash method of determining income and expenses is valid for the first group of exchange rate differences.
In relation to the second group, such a conclusion cannot be drawn, since the implementation of transactions with foreign currency when the official exchange rate of the ruble fluctuates (at the time of receipt of foreign currency and at the time of recognition of income and expenses in connection with the implementation of this currency transaction) precisely generates economic benefit (income ) or additional costs (expenses) of the taxpayer when fulfilling obligations expressed in foreign currency.
ExampleOn February 25, 2003, Russian organization "A", which uses the cash method of determining income and expenses for tax purposes, receives an interest-free loan from a foreign counterparty - organization "B" - in the amount of 10,000 US dollars on the terms of a one-time repayment for the period of September 30, 2003. The official exchange rate as of February 25, 2003 is 30 rubles per one US dollar. The official US dollar exchange rate as of March 31, 2003 was 33 rubles. The official US dollar exchange rate as of June 30, 2003 was 31 rubles. The official US dollar exchange rate as of September 30, 2003 was 29 rubles. The loan to LLC A was repaid on September 30, 2003. Based on the conditions of the example given, LLC “A” reflects the corresponding entries in its accounting: 02/25/2003 Debit 52 Credit 66 - in the amount of 300,000 rubles (receiving a loan) 03/31/2003 Debit 91 Credit 66 - in the amount of 30,000 rubles (negative exchange rate difference) 06/30/2003 Debit 66 Credit 91 - in the amount of 20,000 rubles (positive exchange rate difference) 09/30/2003 Debit 66 Credit 52 - in the amount of 290,000 rubles (loan repayment) 09/30/2003 Debit 66 Credit 91 - in the amount of 20,000 rubles (positive exchange rate difference) |
When calculating the amount of income by a taxpayer who determines income and expenses using the accrual method, in tax accounting for the purpose of calculating the tax base for income tax, the taxpayer, in accordance with the requirements of Articles 250 and 265 of the Tax Code of the Russian Federation, reflects transactions similar to those reflected in accounting.
However, the use of this approach when determining the tax base for income tax in relation to taxpayers using the cash method is not consistent with the provisions of Article 273 of the Tax Code of the Russian Federation, in accordance with paragraph 2 of which the date of receipt of income when applying the cash method is the day of receipt of funds in bank accounts and (or) to the cash desk, receipt of other property (work, services) and (or) property rights, as well as repayment of debt to the taxpayer in another way.
Article 273 of the Tax Code of the Russian Federation, stipulating the date of occurrence of income under the cash method, focuses on the moment the taxpayer actually receives the corresponding benefit in the sense of Article 41 of the Tax Code of the Russian Federation. When considering the legality of including exchange rate differences in the tax base for income tax when applying the cash method, it is necessary to clearly understand the specificity of the moment of income occurrence in this case - the moment of actual receipt of income (or savings in one form or another).
In relation to the considered example, a taxpayer using the cash method of forming the tax base for income tax must reflect the following entries for tax accounting purposes:
09/30/2003
Debit 66 Credit 50 (51) - in the amount of 290,000 rubles (loan repayment)
09/30/2003
Debit 66 Credit 91 - in the amount of 10,000 rubles (positive exchange rate difference)