Reducing the time required for desk audit of VAT returns
The time frame for desk audits of VAT returns, compared to the general time frame for audits of returns for other taxes, has been reduced to:
- 2 months (clause 2 of article 88 of the Tax Code);
- 1st month - as part of a pilot project conducted by the Federal Tax Service.
The audit will be carried out within 2 months from the date of submission of such a tax return.
As a general rule, the day of submission of the declaration is considered:
- the date of sending the postal item with a description of the attachment - if the declaration was sent by mail;
- date of sending – if the declaration was submitted via TKS or through your personal account.
However, we note that tax authorities have their own understanding of the date from which they will begin conducting an audit.
In their opinion, the period for holding a “camera meeting” begins from the day the Federal Tax Service Inspectorate receives the declaration. In this case, the date of receipt by the tax authority of the tax return and the date of the actual start of the desk tax audit of this tax return may not coincide (letter of the Ministry of Finance of Russia dated December 22, 2017 No. 03-02-07/1/85955).
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For what reasons will the declaration not be accepted in 2021, but the “camera chamber” will be conducted more thoroughly?
Three deadlines for a desk audit of a VAT return
GLAVBUKH-INFO
The purpose of the audit of VAT-related transactions is to establish compliance of the procedure for calculating VAT with the requirements of tax legislation.The objectives of the audit of VAT-related transactions are:
— assessment of the state of synthetic and analytical accounting for VAT calculations;
— checking the formation of the tax base, the application of tax benefits and tax deductions;
— control over the reflection of current tax obligations to the budget in accounting and tax reporting;
— checking the organization’s compliance with tax legislation when forming the tax base for VAT, the completeness and timeliness of tax payment to the budget.
Main regulatory documents:
— Tax Code of the Russian Federation, Chapter 21 of the NKRF;
— Rules for maintaining logs of received and issued invoices, purchase books and sales books when calculating value added tax, approved by Decree of the Government of the Russian Federation dated December 2000 No. 914.
Documents provided to the auditor: balance sheet (Form No. 1), profit and loss statement (Form No. 2), general ledger or balance sheet, order on the organization’s accounting policy, accounting registers for accounts 68 “Calculations for taxes and duties”, sub-account “ Calculations for value added tax", 19 "Value added tax on acquired assets", tax returns, purchase book, sales book, invoices, primary documents confirming the receipt of inventory items.
Work during a VAT audit can be divided into three stages: introductory, main and final.
Introductory stage
The main objective of the audit of VAT-related transactions is to control the correctness of the formation of the amounts of tax obligations to the budget. For this purpose, the auditor must perform the following procedures:
— evaluate the accounting and tax accounting system;
— assess audit risks;
— calculate the level of materiality;
— identify the main factors influencing tax indicators;
— analyze the organization of document flow and study the functions and powers of the services responsible for the calculation and payment of taxes.
Completing the listed procedures allows you to consider existing taxation objects, the compliance of the taxation procedure applied by the organization with the norms of current legislation, and assess the level of tax obligations and potential tax violations.
The auditor must make a request for the organization to provide the following basic documents: VAT tax returns (including all updated calculations), purchase books and sales books, invoices, certificates of work (services) performed, invoices, accounting registers.
Main stage
At this stage, an in-depth audit of tax accounting areas is carried out, where problem areas have been identified, taking into account the level of materiality. To do this:
— assessment of the correctness of determining the taxable base for VAT;
— verification of tax reporting submitted by the organization according to established forms;
— calculation of tax consequences for organizations in cases of incorrect application of tax legislation.
Based on the results of the audit, recommendations are developed and presented for the organization’s use of tax benefits and proposals for creating a system of internal control in the organization over the correctness of VAT calculations.
The main objects of inspection for the type of audit under consideration and the corresponding audit procedures are given in Table. 12.1.
Table 12.1 Objects of VAT audit and corresponding audit procedures
The auditor should pay attention to the organization's execution of invoices, their compliance with the standards specified in the Rules for maintaining logs of received and issued invoices, purchase books and sales books when calculating value added tax, namely, check:
- how the organization applies the new procedure for correcting invoices. The essence of the new rules is that the buyer receives the right to deduct only in the tax period when he has a corrected version of the invoice;
- what details are contained in the new invoice. It is necessary to pay attention to the signatures on the invoices. If the invoices are signed by persons other than the director and chief accountant, then the auditor must request an order on the basis of which the right to sign was transferred;
— what address is indicated on the invoice (legal or actual). In accordance with the letter of the Ministry of Finance of Russia dated ..2006 No. 03-04-09/15, the address must be the same as indicated in the constituent documents. If both the legal and actual addresses are indicated in the constituent documents, then both addresses can be indicated on the invoice.
The main types of violations that can be identified as a result of an audit of VAT-related transactions:
— incorrect application of tax benefits;
— violation of the procedure for determining tax deductions;
— absence or violation of the organization’s internal control system over the correct calculation of VAT.
The final stage
Upon completion of the work, the auditor forms an opinion based on the results of the audit of this area of accounting, draws up a package of working documents, formulates the part of the audit report related to the area of the audit, and presents it together with the working documentation (Appendix 12.1) to the head of the audit.
Appendix 12.1
Procedures for auditing VAT-related transactions
Procedure 1. Checking the correctness of VAT calculation
Accrued VAT, rub.
| Revenue from sales (line 010 of form No. 2), rub. | Data deviation, rub. | Explanations of deviations* | |
| (A) | (b) | (c) = (a) - (b) x 18% | (G) |
* The auditor should pay attention to credit turnover in account 91 “Other income and expenses”, which may also relate to revenue subject to VAT.
Procedure 2. Checking the correct application of VAT deductions
| VAT deductible, rub. | Amount of purchases (turnover on account credit 60), rub. | Amount of purchases related to capital construction (turnover on account credit 60), rub. | Deviation, rub. | Brief explanation of deviations* |
| (A) | (b) | (V) | (d) = (a) - ((b) -(c)) X x18/118% | (d) |
* The auditor should pay attention to interest on trade loans and bills of exchange recorded in account 60 “Settlements with suppliers and contractors”.
Procedure 3. Checking the correct calculation of VAT on advances
| Accounting data | Tax return data | Analytical calculation of net VAT on advances received, rub. | Net VAT advances according to declarations, rub. | Data deviation | Explanations of deviations | ||
| Balance of advances received at the end of the year on account credit 62 “Settlements with buyers customers”, rub. | Balance of advances received for the beginning of the year on account credit 62 “Settlements with buyers customers”, rub. | VAT calculated on the amount of payment/partial payment for future deliveries, rub. | VAT subject to deduction on previously received payment amounts / partial payment on account of upcoming deliveries, rub. | ||||
| (A) | (b) | (V) | (G) | (e) = ((a) —- (b)) x 18/118 | (e) = (c) - (d) | (g)=(f) - (e) | (And) |
Procedure 4. Checking the correct formation of the purchase book and sales book
| Month | Total VAT accrued according to the sales book, rub. | Total VAT accrued according to the tax return, rub. | Deviations, rub. | Total presentations for VAT deduction according to the purchase book, rub. | Total VAT deduction claims according to the tax return, rub. | Deviations, rub. |
| (A) | (b) | © = (a) - (b) | (a1) | (61) | (c1) = (a1) - (b1) |
Procedure 5. Comparison of turnover on account 68 subaccount “VAT calculations*
| Check | According to client | According to the audit | Deviations | ||||||||||||||||
| Saldona beginning period | Turnover period | Saldona end period | Balance at the beginning period | Period transactions | Balance at the end of period | Saldona beginning period | Period transactions | balance at the end of period | |||||||||||
| Code | Name | d | To | d | To | d | To | d | To | d | To | d | To | d | To | d | To | d | To |
| 68 | Value added tax calculations | Data should be comparable to last year's data | Data should be comparable to last year's data | Tax paid | Tax accrued | Determined by calculation | Determined by calculation | ||||||||||||
* Based on the correspondence data of the accounts, the auditor must check the data reflected in the general ledger (or balance sheet) and identify deviations.
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Pilot project of the Federal Tax Service on verification of declarations
With reporting for the third quarter of 2021, a pilot project of the Federal Tax Service began to reduce the period of desk verification of the VAT return to 1 month (letter of the Federal Tax Service dated October 6, 2020 No. ED-20-15 / [ email protected] ).
Organizations that:
- declared in the declaration the right to a VAT refund;
- meet certain conditions. For example, for the previous 3 years they paid taxes in a larger amount than declared in the declaration.
In this case, tax officials will check the company that submitted the declaration for compliance with the established criteria of integrity, and the declaration itself for errors and discrepancies with the data of the company's counterparties.
Previously on the topic:
Pilot project to reduce VAT delays: technology of application
Will the decision based on the results of the “camera chamber” be canceled if the deadline was violated?
Table 2. Common errors in the VAT return leading to requests for clarification
| Error | Description of the error and correct order |
| Incorrect application of KVO 26 in section 9 | Code 26 is indicated incorrectly instead of code 01 |
| Incorrect reflection of customs declaration | Incorrect instruction:
|
| Advance payments are reflected incorrectly | Incorrect indication of the counterparty's quotation code and tax identification number. The correct order is:
|
| Control ratios do not converge | Most often, the data in section 3 does not correspond to the data in sections 8 and 9. |
| Discrepancy according to KVO 25 | Code 25 should be used to indicate in the purchase book a transaction for which the validity of applying a 0% VAT rate has been confirmed. The entry is compared with the corresponding entry with KVO 21 in the sales book |
| Discrepancies in the amounts of deductions declared by the taxpayer and VAT paid by the counterparty | The counterparty did not pay (did not pay in full) the amount of tax declared by the taxpayer for deduction or did not file a declaration for the audited period |
VAT: working with Applications. Extended VAT return
To open a VAT form in the Kontur.Extern system, fill out or download ready-made VAT report files and applications, you must perform the following steps:
1. Go to the “ Federal Tax Service” menu > “Fill in the system.”
2. In the list of forms you must select “VAT».
3. Select the reporting period and click “Fill out the report ” . At this stage, a draft of the VAT form for a given period is selected.
4. To download the finished declaration file, click on the button “Download declaration " . To edit the downloaded declaration or fill it out from scratch in Kontur.Extern, click on the “Edit ” link .
4. After clicking on the “Edit ” , a form for filling out VAT will open. You should fill out the required sections and click “Save and close " . Sections 8-12 are not completed in the declaration itself; they must be added as appendices.
5. To add information from the book of purchases, sales and other attachments to the declaration, you must click “Add attachments».
6. After clicking on the “Add applications " you will be able to:
- Bulk download attachments to the declaration using the “Download from file” link»;
- fill in the information in the system, or add applications one by one by clicking on the “Fill in the system” link».
Applications should be uploaded in xml format. The file format must comply with Order of the Federal Tax Service of the Russian Federation dated October 29, 2014 N ММВ-7-3/ [email protected]
It is allowed to download books of purchases/sales, journals of received and issued invoices in xls formats (must be generated in accordance with Decree of the Government of the Russian Federation N 1137). Excel files will be automatically converted to xml format.
You can upload several application files of the same type to Kontur.Extern, for example, sales books for different branches. Before sending, such files will be combined into one application.
6.1 When you click on the “Download from file ” , you have the opportunity to select one or more files: the declaration file and/or its attachments. In the window that appears, select the files to upload and click “Open "
.
6.2 To fill in the data in the system, you must select “Add applications ” , specify the required applications and click “Add ”.
7. After adding/downloading applications on the page for working with a VAT package, it will be possible to:
- Fill in application data by clicking on the “Edit” link».
- Upload a new file to replace the existing one by clicking on the “Replace file” link»;
- Delete applications by clicking on the “Delete” link».
- Print the data by clicking on the icon.
If you upload finished files, it will take time to check them.
For the purchase book (section
and sales books (section 9), as well as additional sheets for them (sections 8.1 and 9.1), the total amounts from each file are displayed. The purchase books will display one total value, the sales book will display all 3 values by clicking to the link “Tax amounts " . If you upload several purchase books, the total amounts of the file that results from the merger will be displayed.
When you click on the “Edit ” , a form will open to fill out. By default, a line will be added to enter data for one invoice. To enter other invoices, you need to click “Add transaction”. After filling in the data, you must click “Close”. Work with other applications in a similar way.
8. You can check the data when filling out the application. To do this, click “Check” on the left; the built-in control protocol will open. When you click on an error, the system will tell you where the error was made.
9. Also, to view the verification protocol, you can click on the line with the number of errors or warnings, and the monitoring protocol will open.
10. After correcting all errors, the “Check and submit ” will become active. After clicking this button, VAT and applications will be checked. If no errors are found, a page for signing and sending will open.
11. By clicking the “Sign and send ” , the report and attachments will be transferred to the Federal Tax Service for further processing.
