The organization has two checkpoints, which should be specified in the contract. Which checkpoint should be included in contracts, checkpoint by largest or checkpoint by location? How many checkpoints can an organization have?

Has two checkpoints received for different reasons. He received one checkpoint when registering with the tax authority at his location, and the second - when registering with the same MIFTS as the largest taxpayer. Which checkpoint must be indicated when filling out tax returns, invoices and other documents?

Having considered the issue, we came to the following conclusion:

When filling out tax returns, invoices and other documents for your organization, you should indicate the checkpoint assigned when registering the organization as the largest taxpayer.

Rationale for the conclusion:

Clause 1 of Art. 83 of the Tax Code of the Russian Federation determines that for the purpose of conducting tax control, organizations are subject to registration with the tax authorities, respectively, at the location of the organization, the location of its separate divisions, at the location of the real estate and vehicles owned by it, as well as on other grounds, provided for by the Tax Code of the Russian Federation.

At the same time, the Russian Ministry of Finance has the right to determine the specifics of accounting of the largest taxpayers by the tax authorities.

Features of registration of the largest taxpayers (hereinafter - Features) were approved by Order of the Ministry of Finance of Russia dated July 11, 2005 N 85n.

Thus, clause 4 of the Peculiarities establishes that the interregional (interdistrict) inspection of the Federal Tax Service of Russia for the largest taxpayers, within three days after receiving documents from the inspection of the Federal Tax Service of Russia at the location of the organization, sends by registered mail with notification to the largest taxpayer a notice of registration with the tax authority as the largest taxpayer in form N 9-KNU (approved by order of the Federal Tax Service dated April 26, 2005 N SAE-3-09/178).

In turn, clause 5 of the Features provides that when registering the largest taxpayer with the interregional (interdistrict) inspectorate of the Federal Tax Service of Russia for the largest taxpayers, the taxpayer identification number (TIN) assigned to the inspectorate of the Federal Tax Service of Russia at the location of the organization does not change. The interregional (interdistrict) inspectorate of the Federal Tax Service of Russia for the largest taxpayers assigns the largest taxpayer a new reason for registration code (KPP).

The tax return form for corporate income tax, as well as the Procedure for filling it out (hereinafter referred to as the Procedure) were approved by order of the Federal Tax Service dated March 22, 2012 N ММВ-7-3/174@.

Thus, clause 3.2 of the Procedure indicates that when filling out the Title Page (Sheet 01), the largest taxpayers enter the TIN and KPP on the basis of the Notification of registration with the tax authority of a legal entity as the largest taxpayer in Form N 9-KNU.

Consequently, when filling out a tax return for income tax, the KPP assigned to the organization when registering as the largest taxpayer is indicated.

Thus, in our opinion, we can conclude that currently the authorized bodies have developed a uniform approach to indicating the checkpoint in tax returns.

The same checkpoint should also be indicated on line 2b of the invoice. Similar explanations were repeatedly given by employees of official bodies (see, for example, letters from the Ministry of Finance of Russia dated September 17, 2009 N 03-07-09/47, dated October 22, 2008 N 03-07-09/33, dated May 14, 2007 N 03-01- 10/4-96, dated 04/20/2007 N 03-07-11/114).

The indicated letters from the financial department also explain that the “Payer checkpoint” field in payment documents for the payment of taxes is filled in in a similar manner.

Prepared answer:
Expert of the Legal Consulting Service GARANT
, member of the MoAP Zavyalov Kirill

The answer has passed quality control

The material was prepared on the basis of individual written consultation provided as part of the Legal Consulting service.

Considering that some business entities may be registered with the tax service under two checkpoints, the question often arises of which checkpoint should be indicated for the largest taxpayer in the invoice when it is generated.

Let's consider the concept, features, structure of the checkpoint, and the features of generating an invoice for enterprises with this status.

Checkpoint of the largest taxpayer: concept and features of registration

Registration with the tax office as a major taxpayer is regulated by clause 1 of Article 83 of the Tax Code of the Russian Federation and the Appendix to Order of the Ministry of Finance of the Russian Federation No. 85n dated July 11, 2005, according to which such organizations are registered:

in the interregional Federal Tax Service, where the enterprise is assigned the appropriate reason for setting code (RPC). The assigned identifier determines:

the reason for registering the subject for tax purposes;
belonging to a specific regional tax office.

at the location of the organization itself, and the real estate and vehicles owned by it.

Thus, if the property at the disposal of the largest taxpayer is registered simultaneously in several regional branches of the Federal Tax Service, the organization will have more than two checkpoints as the largest taxpayer - for each of its separate structures its own, assigned by the tax authority, on whose jurisdiction each of the multiple objects is located .

Checkpoint of the largest taxpayer: where to see the assigned code

To confirm the fact of registration of the organization, a notification is issued, which indicates the checkpoint assigned to the payer. The document must be drawn up in accordance with Form No. 9-KNU, approved by Order of the Federal Tax Service of the Russian Federation No. SAE-3-09/178@ dated April 26, 2005.

However, this notification may not always be at hand. How to find out the checkpoint of the largest taxpayer in this case?

Using the TIN assigned to the business entity - on the official website of the Federal Tax Service of the Russian Federation or special online services, by entering the TIN of the organization, you can obtain the registration data of the desired object.

Code structure

The nine-digit structure of the checkpoint of the largest taxpayer is formed by four information blocks:

block 1

the first two digital characters – the constant value “99”, demonstrate that the identifier is assigned specifically to the largest taxpayer, and the company is registered for tax purposes with the Interregional Inspectorate in this status;

block 2

the third and fourth digits indicate the specific tax authority with which registration was made. The third character in the code meaning is “7”, unchanged. Indicates that the registration was carried out by an interregional tax authority. The fourth character is changeable and shows the number assigned to the interregional NI. That is: the value “71” in block 2 reads as follows: the largest taxpayer was registered with the Interregional Federal Tax Service No. 1;

block 3

digital symbols in the fifth and sixth positions determine the attribute of inclusion in the group of largest taxpayers. In the identifier code, this is the static value “50”;

block 4

from the seventh to the ninth digit of the code. A variable value found in the following options:

“001” – indicates that the payer is registered for tax purposes at the place of location;
“006 – 008” - assigned to taxpayers registered at the place of registration of real estate or vehicles owned by it;
“002 – 005”, “031” and “032” - indicate the registration of the subject at the place of regional affiliation of its separate objects.

Using the above structure, we give an example of decoding the most common checkpoint code 997650001 of the largest taxpayer:

The business entity is registered as the largest taxpayer of the interregional Federal Tax Service No. 5, assigned to this group in accordance with the Federal Tax Service directory, and registered in this status at its location.

Which checkpoint should be indicated on the invoice?

Questions often arise related to the generation of invoices by an organization registered as the largest taxpayer; which checkpoint should be indicated in the relevant information fields of this document?

The answer to this question is clear: when filling out the invoice, in line “2 b” you should enter the checkpoint assigned to the business entity as the largest taxpayer (i.e., the identifier assigned by the interregional inspectorate), and in line “3” - the registration address, according to location.

This conclusion was justified in the letter of the Ministry of Finance No. 03-07-09/49236 dated 08/20/2015. It states that business entities registered as major taxpayers submit a VAT return directly to the tax authority where it was registered in this status, and for productive administration of this type of tax, it is the checkpoint assigned in the interregional Federal Tax Service that should be use when generating an invoice.

Tax authorities constantly require us to be careful when choosing suppliers, and it is accountants who are forced to carefully check all documents and pay attention to all kinds of details. We have long been accustomed to these abbreviations - INN and KPP. And it seems that no questions can arise here. Meanwhile, if many people have an idea about the TIN and know where it is check, then, besides how the checkpoint is deciphered, as a rule, no one else knows anything about it. These are the questions we are asked.

The checkpoint will help determine who you are dealing with: an organization or its branch

E.N. Dorofeeva, Orenburg

For all our counterparties, the checkpoint ends with 01001. But recently, while filling out a payment form, I discovered some strange checkpoint from a new supplier - the last numbers are 43001. How do you understand what this means?

: This checkpoint means that you are transferring money to a branch of your counterparty A.

The gearbox is a 9-digit digital code (hereinafter - the Order).

1Art. 65 of the Constitution of the Russian Federation

For example, KPP 770601001 means that the organization is located in Moscow and the Federal Tax Service of Russia No. 6 for Moscow registered it as a taxpayer at its location (code 01).

The classifier “Tax Authority Designation System” (SONO) can be found: website of the Federal Tax Service of Russia

If the 5th and 6th digits of the checkpoint (ZZ) are not 01 (for example, like your counterparty - 43), then this means that the organization was registered on other grounds.

A complete list of reason codes for registration is given in the departmental directory (SPPUNO) approved 11.10.99. But this guide is an internal document. And if previously it was posted for public viewing on the official website of the Federal Tax Service, now it is problematic to find it in the public domain. But we will tell you what some codes mean.

* These codes are not currently assigned I Letter of the Federal Tax Service of Russia dated 02.06.2008 No. CHD-6-6/396@. But checkpoints with these codes assigned earlier remain valid.

Gearbox may change

A.L. Zimina, Moscow

Our counterparty's checkpoint has changed. OGRN and TIN remain the same. What does this mean? Moving? Or could there be other options?

: The organization may have a new checkpoint, in particular And clause 2.1.4 of the Procedure:

Most often, the checkpoint changes if an organization moves and has to register with another tax office. And clause 2.1.4 of the Procedure; subp. “c” clause 1, clause 5 art. 5 of the Federal Law of 08.08.2001 No. 129-FZ “On state registration of legal entities and individual entrepreneurs”. For example, if the checkpoint used to be 77 07 01001, and then became 77 19 01001, this means that your counterparty was registered with the Federal Tax Service Inspectorate No. 7 for Moscow, and now with the Federal Tax Service Inspectorate No. 19 for Moscow.

If other numbers have changed in the checkpoint, for example, the reason code for the statement, then it is better to check with your counterparty to see if it is correct.

Different organizations may have the same checkpoint

V.S. Terentyeva, Moscow

Three of our counterparties have the same checkpoint. Is there something wrong with them? Or is this possible?

: Yes, it's possible. Unlike the TIN (a unique number that is assigned to an organization once at the time of registration and does not change I clause 7 art. 84 Tax Code of the Russian Federation; clause 3.1 of the Procedure), the checkpoint determines whether an organization belongs to a particular tax authority, as well as the reason for registration. Therefore, it may be the same for organizations registered with the same tax office for the same reasons. m clause 1 of the Order.

The branch, when issuing an invoice, indicates its checkpoint in it

A.T. Seliverstova, Ekaterinburg

We purchased goods from a branch of our counterparty. He issued us an invoice on behalf of the parent organization, and indicated his own (branch) checkpoint. Is it correct? Can we be denied a deduction if the wrong checkpoint is indicated?

: Your counterparty did everything correctly. The regulatory authorities believe that when selling goods through separate divisions, the invoice must be issued on behalf of the parent organization, that is, in lines 2, 2a, 2b the name, tax identification number, location of the organization itself must be indicated, and in lines 2b and 3 - KPP and address of a separate division (branch )Letters of the Ministry of Finance of Russia dated May 23, 2011 No. 03-07-09/12, dated April 1, 2009 No. 03-07-09/15, dated October 22, 2008 No. 03-07-09/33; Letter of the Federal Tax Service of Russia for Moscow dated 07/07/2010 No. 16-15/071188.

As for the VAT deduction, previously tax authorities quite often refused it in the absence of a checkpoint or its incorrect indication, but the courts never supported them And Resolution of the Federal Antimonopoly Service of the Moscow Region dated December 17, 2008 No. KA-A40/11795-08; FAS NWO dated October 23, 2008 No. A56-39361/2007; FAS North Caucasus Region dated June 4, 2008 No. F08-3055/2008, dated October 28, 2008 No. F08-6493/2008. And after amendments were made to the Tax Code of the Russian Federation And clause 2 art. 169 Tax Code of the Russian Federation, according to which errors in invoices that do not interfere with the identification of the seller are not grounds for refusal of a deduction, there should be no problems at all. After all, the checkpoint does not interfere with such identification.

KPP is not assigned to entrepreneurs

T.V. Makarova, Samara

Our buyer, an entrepreneur, sent us the details where the checkpoint is indicated and stated that he really has the code, but he cannot find a document confirming this. Do individual entrepreneurs have checkpoints?

: No, KPP is not assigned to entrepreneurs. It is assigned only to legal entities m clause 1 of the Order; forms No. 1-1-Accounting, No. 2-3-Accounting, approved. By Order of the Federal Tax Service of Russia dated December 1, 2006 No. SAE-3-09/826@.

When issuing a payment order in which the payee is an entrepreneur, the “Checkpoint (103)” field is not filled in I clause 2.10 of the Regulations on non-cash payments in the Russian Federation, approved. Bank of Russia 03.10.2002 No. 2-P. However, if your bank asks you to fill in this detail, you can enter 0.

The largest taxpayers are assigned an additional checkpoint

A.G. Efimova, Moscow

We noticed that in the invoices issued by our counterparty, the checkpoint has changed - it used to start at 7701, and now at 9971. But it indicates the same address as before. What could this mean? Will this cause us to have problems with deducting input VAT on such invoices?

: The new checkpoint means that your counterparty has acquired the status of the largest taxpayer. And such taxpayers are registered with one of the Interregional Inspectorates for the largest taxpayers and are assigned an additional CP P clause 1 art. 83 Tax Code of the Russian Federation; Order of the Ministry of Finance of Russia dated July 11, 2005 No. 85n; clause 5 of the Criteria... approved. By Order of the Federal Tax Service of Russia dated May 16, 2007 No. MM-3-06/308@. Thus, they have two checkpoints: at the place of registration as the largest taxpayer and at the location.

Interregional inspectorates for the largest taxpayers have a code in which the first two digits are 99, and the next two digits indicate the inspection number (for example, 9971, as in your case, - Interregional Inspectorate of the Federal Tax Service for the largest taxpayers No. 1, 9972 - Interregional Inspectorate of the Federal Tax Service for the largest taxpayers taxpayers No. 2, etc. )Classifier “Tax Authorities Designation System” (SONO).

The Ministry of Finance recommends that invoices indicate the checkpoint assigned to the taxpayer as the largest. True, if your supplier indicates in the documents the checkpoint assigned to him at his location, this will not be considered a violation m Letter of the Ministry of Finance of Russia dated May 14, 2007 No. 03-01-10/4-96. And you shouldn’t have any problems with VAT deduction anyway. O clause 2 art. 169 Tax Code of the Russian Federation.

Registration reason code (KPP) is a nine-digit code that is assigned to an organization upon registration.

The checkpoint is necessary because some companies are registered with several tax inspectorates: not only at their legal address, but also at the location of separate divisions, real estate and taxable vehicles.

Since everyone must have the same TIN, the tax authorities introduced an additional code - KPP.

This code shows why the company is registered with this inspection.

One company may have several checkpoints.

A reason code for registration is assigned for each basis for registration, including the location of the organization itself, its separate subdivisions (SU), land plots and other real estate, and transport.

Unlike the TIN, the reason code for registering an organization may change.

So, if an organization changes its address to another address that belongs to a different tax office, the company will be assigned a new checkpoint.

The value of the checkpoint can be found out from the certificate or notification of registration.

The checkpoint of the organization at its location is also indicated in the Unified State Register of Legal Entities (USRLE).

The first four digits of the checkpoint represent the code of the tax authority with which the organization is registered.

Of these, the first two digits are the region code, and the third and fourth digits are the tax office code (number).

For example, a checkpoint starting with 7713 means that the organization is registered with the Federal Tax Service No. 13 for Moscow.

The fifth and sixth digits of the checkpoint indicate the reason for registration.

For example:

numbers 01 mean that the checkpoint was assigned to the organization in connection with registration at its location;

numbers 02, 03, 04, 05, 31 or 32 mean that the checkpoint is assigned to the organization at the location of the separate division of the organization;

numbers 06-08 mean that the checkpoint is assigned to the organization at the location of the real estate it owns (thus, vehicles are not affected), depending on the type of property;

numbers 10-29 - mean that the checkpoint is assigned to the organization at the location of its vehicles, depending on the type of vehicle;

the numbers 50 mean that the checkpoint was assigned in connection with registration as the largest taxpayer.

The last three digits of the checkpoint represent the serial number of the organization's registration with the Federal Tax Service on the basis for which this checkpoint was assigned to it.

Organizations must indicate TIN and KPP in all documents intended for tax inspections.

Thus, the organization’s checkpoint should indicate:

in all tax returns and calculations;

in payment orders, including payment orders for the payment of taxes and insurance premiums;

in invoices and other documents where the checkpoint must be indicated.

Since an organization may have several checkpoints, the document indicates the code assigned by the tax office, which is intended for this document.

Still have questions about accounting and taxes? Ask them on the accounting forum.

Registration reason code (RPC): details for an accountant

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Please clarify which checkpoint must be indicated in the Company's contracts and invoices: checkpoint assigned in connection with the registration of the Company as the largest taxpayer, or checkpoint assigned in connection with registration at the location. In accordance with Art. 421 of the Civil Code of the Russian Federation, the terms of the contract are determined at the discretion of the parties, with the exception of cases when the content of the relevant condition is prescribed by law or other legal act. None of the current regulations establishes the indication in the contract of such details as the reason code for registration as a taxpayer as a mandatory condition of the contract. Accordingly, the parties have the right, when concluding an agreement, to indicate any of the checkpoints assigned to the organization, including several codes, as well as not to indicate any. Article 169 of the Tax Code of the Russian Federation specifies the mandatory details that must be reflected in the invoice.

The organization has two checkpoints, which one should I indicate?

The peculiarities stipulate that when registering the largest taxpayer with the interregional (interdistrict) inspectorate of the Federal Tax Service of Russia for the largest taxpayers, the taxpayer identification number (TIN) assigned to the inspectorate of the Federal Tax Service of Russia at the location of the organization does not change. The interregional (interdistrict) inspectorate of the Federal Tax Service of Russia for the largest taxpayers assigns the largest taxpayer a new registration reason code (KPP). Consequently, the largest taxpayer is assigned two KPP values on the grounds established by the Tax Code of the Russian Federation.

A similar point of view is expressed in the letter of the Federal Tax Service N ШТ-8-09/278 (see also decision of the Supreme Arbitration Court of the Russian Federation N 7448/04). The form of the tax return for corporate income tax, as well as the Procedure for filling it out (hereinafter referred to as the Procedure) were approved by order of the Federal Tax Service N ММВ-7-3/

Indication of the checkpoint in the details of the parties

Details of a separate division can be indicated as additional information in the line “Consignee and his address”. Considering that settlements with the seller are carried out from the current account of the parent organization, the payment order must indicate the checkpoint of the parent organization.

Rationale for the conclusion: In accordance with Art. 11 of the Tax Code of the Russian Federation, a separate subdivision is any subdivision territorially isolated from the organization, at the location of which stationary workplaces are equipped. Recognition of a separate division of an organization as such is carried out regardless of whether its creation is reflected or not reflected in the constituent or other organizational and administrative documents of the organization, and on the powers vested in the specified division.

If a company has two checkpoints

Attention

The procedure indicates that when filling out the Title Page (Sheet 01), the largest taxpayers enter the TIN and KPP on the basis of the Notification of registration with the tax authority of a legal entity as the largest taxpayer in Form N 9-KNU. Consequently, when filling out a tax return for income tax, the KPP assigned to the organization when registering as the largest taxpayer is indicated.

Similar rules are contained, in particular, in clause 3.2 of the Procedure for filling out a tax return for the property tax of organizations (approved by order of the Federal Tax Service N ММВ-7-11/895), in clause 20 of the Procedure for filling out a tax return for value added tax ( approved by order of the Ministry of Finance of Russia N 104n).
Therefore, the taxpayer must independently decide whether to be guided in a specific situation by the explanations of the Russian Ministry of Finance. We note that in accordance with paragraphs. 5 p. 1 art. 32 of the Tax Code of the Russian Federation, tax authorities are obliged to be guided by written explanations of the Ministry of Finance of Russia on the application of the legislation of the Russian Federation on taxes and fees.

However, from the point of view of specialists of the Ministry of Finance of Russia, the Tax Code of the Russian Federation “does not establish the obligation of tax authorities to be guided by written explanations of the Ministry of Finance of Russia addressed to specific applicants (due to the fact that these explanations do not contain legal norms), but obliges tax authorities to be guided by explanations addressed to the Federal Tax Service of Russia "(letter of the Ministry of Finance of Russia dated 08/07/2007 N 03-02-07/2-138). Please note that, based on the provisions of clause.

8 tbsp. 75 and paragraphs. 3 p. 1 art.

The organization has two checkpoints, which one should be specified in the contract?

The plot is as follows: The agreement was concluded between two legal entities - A and B. Organization A is registered in Samara. Organization B is registered in Moscow.

Info

But it is also registered in Samara (a separate division that is not a branch or representative office. A and B (tenant) enter into a lease agreement for premises in Samara.

Initially, in the contract, the parties mistakenly indicate the incorrect checkpoint of organization B. Since accounting is carried out through the 1C program, organization A cannot issue a correct invoice with the correct checkpoint (data is taken from the signed agreement).

Important

Therefore, it is necessary to make changes to the contract. What checkpoint must be indicated in the contract? Organization A believes that it is necessary to indicate in the Agreement (and invoice, respectively) the checkpoint of the parent organization, i.e. at the legal address in Moscow. Indication of the checkpoint separately. divisions in Samara are impossible, because

the contract cannot be concluded with obos.
Consequently, when filling out a tax return for income tax, the KPP assigned to the organization when registering as the largest taxpayer is indicated. Similar rules are contained, in particular, in clause 3.2 of the Procedure for filling out a tax return for the property tax of organizations (approved by order of the Federal Tax Service dated November 24, 2011 N ММВ-7-11/895), in clause 20 of the Procedure for filling out a tax return for tax for added value (approved by order of the Ministry of Finance of Russia dated October 15, 2009 N 104n). Thus, in our opinion, we can conclude that currently the authorized bodies have developed a uniform approach to indicating the checkpoint in tax returns.

The same checkpoint should also be indicated on line 2b of the invoice.
The form and composition of the invoice indicators are established by the Rules for filling out the invoice, approved by Decree of the Government of the Russian Federation of December 26, 2011 N 1137 (hereinafter referred to as the Rules). Appendix No. 1 to the Rules stipulates that the invoice must reflect:

in line 6 - the full or abbreviated name of the buyer in accordance with the constituent documents;
in line 6a - the location of the buyer in accordance with the constituent documents;
in line 6b - identification number and code of the reason for delivery to the taxpayer-buyer's account.

At the same time, the new Rules that have come into force, like the previously in force, do not contain any explanations on the issue under consideration, in contrast to the procedure for filling out line 2b “TIN/KPP of the seller”, in which, when selling goods through a separate division, the KPP of the corresponding division is indicated.
Accordingly, a separate division by itself cannot take advantage of the right to deduction; only the parent organization has this right, since it is this organization that is the VAT payer. Consequently, it is the name, location and TIN of the parent organization that must be indicated in invoices, in the lines related to the buyer (6, 6a and 6b) (see also letter of the Ministry of Finance of Russia dated 08/09/2004 N 03-04-11/127 ). In this case, the details of a separate division can be indicated as additional information in column 4 “Consignee and his address” (letter of the Ministry of Finance of Russia dated 04/03/2012 N 03-07-09/31). At the same time, taking into account that the specified letter is a response to a private request from the taxpayer, we assume that the position expressed by specialists from the Russian Ministry of Finance can only be due to certain features contained in the text of the request.

Consequently, the largest taxpayer was assigned two KPP values on the grounds established by the Tax Code of the Russian Federation. A similar point of view is expressed in the letter of the Federal Tax Service dated 02.08.2006 N ШТ-8-09/278 (see also the decision of the Supreme Arbitration Court of the Russian Federation dated 25.11.2004 N 7448/04).
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