Managing the organization's tax burden. Tax burden management
Introduction
The work is devoted to the forms and methods of tax management in an enterprise. The relevance of the topic is that taxation management should be carried out not only by the tax authorities, but also by taxpayers, especially organizations.
In most Russian organizations, the tax department is an auxiliary unit. His activities boil down to reflecting completed business transactions in tax reporting and defending the company’s position before the tax authorities during audits. Such a passive approach to organizing tax work often leads to the fact that specialists responsible for calculating payments to the budget strive to take the most conservative position regarding controversial issues, that is, in fact, they try to overpay taxes in order to minimize the risk of additional assessments by tax authorities.
The purpose of the work is to characterize the content of tax management at an enterprise. In accordance with this goal, the following work tasks can be formulated:
review of the main approaches to determining the tax burden on an enterprise
analysis of organizational issues of tax management at the enterprise level
characteristics of tax planning as one of the aspects of financial management
Methodology for managing taxes in an enterprise
Requirements for tax management, as well as for the organizational structure within which it will be carried out, vary depending on the characteristics of the enterprise or group of organizations. However, there are strategic issues that need to be addressed in any enterprise.
determine the goals and objectives of tax management;
establish the status of the tax department in the structure of the enterprise and the mechanisms of interaction between the tax department and other departments of the company;
develop the organizational structure of the tax department;
work out the procedure for interaction between the tax departments of the parent and subsidiary organizations;
develop procedures for monitoring tax management work;
determine criteria for assessing tax management work;
develop procedures and rules for the work of the tax department, internal documents regulating the work of the tax department and its relationship with other departments of the enterprise, as well as determine the necessary tools for its work.
In addition to preparing tax reporting and interacting with tax authorities, the main tasks that management usually sets for the tax department are optimizing current payments to the budget and the tax burden, as well as reducing tax risks. In this case, it is necessary to determine the level of tax risks that the company is willing to accept, acceptable tax planning schemes (for example, an enterprise with state participation can refuse tax planning schemes using foreign organizations), as well as the company’s readiness to change the business structure for tax optimization purposes.
Tax management issues for a particular company should be linked to its strategic goals and objectives.
The tasks of the tax department may also include unifying methods and approaches to calculating taxes by various divisions of the company (or various companies of the group), lobbying the tax interests of the company, increasing the tax literacy of employees, etc.
The strategic goals of the holding's internal audit service are to ensure the efficiency of the financial and economic activities of the holding's organizations and to protect their interests and rights in relations with government agencies and third parties. In the context of the goals, one of the tasks is to optimize the tax burden of the holding organizations, including planning and monitoring the execution of the tax budget.
As for the tasks, at different time stages of the holding’s development they changed both quantitatively and qualitatively depending on external and internal factors. This includes the unification of reporting for all enterprises of the group, and the development of schemes for interaction of the internal audit service with chief accountants and heads of organizations, etc.
For the tax department to operate successfully, responsibility for its activities must be assigned to a representative of senior management, such as the financial director, as is the case in many companies. This will not only ensure the interest of the company’s top management in solving tax problems, but also avoid conflicts of interest between the company’s structural divisions. For example, quite often the tax department reports to the chief accountant of the organization. Such a structure may not be effective enough if the main task facing the tax department is minimizing the tax burden. Since the chief accountant bears personal responsibility for tax violations, this task in a certain sense will contradict his desire to reduce tax risks. Taxes and taxation / ed. M. V. Romanovsky and O. V. Vrubelevskaya. St. Petersburg: Peter, 2008 - P.369.
In order for the tax department to effectively carry out its tasks, it is necessary to create conditions for its work.
In particular, it is necessary to develop internal documents, rules and procedures governing the work of the tax department and its relationship with other departments of the enterprise, as well as to determine the necessary tools for its work (for example, appropriate software).
Examples of such procedures and documents are:
staffing schedule;
job descriptions;
procedures for interaction with other departments within the company;
providing access to legal databases and subscription to the necessary professional literature;
procedures for submitting reports to management, forms of such reports;
procedures for approval of major transactions by an independent consultant;
procedures for participation in the process of operational and long-term financial planning and budgeting.
Particular attention should be paid to the role of the tax department in approving significant transactions and monitoring the correct reflection of their implementation for tax purposes.
It is advisable to involve the tax department in the approval of transactions at least at two stages:
at the stage of planning transactions (new types of activities, marketing initiatives, etc.) to assess the tax consequences and preliminary calculation of the tax burden on the participants in the transaction as a result of the proposed scheme for its implementation, as well as identifying opportunities for more efficient execution of the transaction from a tax point of view;
at the stage of approval of transactions for the final examination of draft agreements formalizing the transaction (with possible clarification of individual wording), and the final assessment of the tax burden.
Organizing such a tax examination will allow you to plan and optimize the tax component of the costs of implementing transactions, as well as reduce tax risks and/or inefficiencies arising from incorrect wording of contracts.
In order to organize the procedure for planning and controlling the tax burden, it is enough to build the process of approving financial documents once, taking into account the tax consequences. It makes sense to maintain a tax department for this purpose only for large companies, which are faced with the task of managing taxes in branches and structuring payments to fiscal authorities. The company does not have a tax department as such - tax management tasks are solved through the joint work of the financial director, lawyer, chief accountant and commercial director.
The approval of transactions takes place in two stages - first, the logic of the transaction is analyzed, and then, after calculating the financial results, a final assessment of the tax burden and legal verification of the documents are carried out.
Within the company, the chief accountant is responsible for the fiscal side of the issue, that is, for the amount of taxes that the company will pay as a result of the implementation of a particular agreement, and the lawyer is responsible for the legal protection of the company’s interests within the framework of this agreement. In general, an agreement is one of the main tools, if not for reducing taxes, then at least for optimizing them over time.
The level and set of tasks assigned to the tax department determine the requirements for the organizational structure of the tax department, the required number of tax specialists and their qualifications.
In many cases, it is advisable to separate the function of preparing tax reporting from the function of developing methodology and tax planning (see Fig. 1). For example, in a large company or an industrial group holding, some tax specialists may be engaged only in tax planning and not participate in the preparation of tax reporting. In smaller companies, a strict division of functions between tax department employees may not be economically justified, and the same people are able to deal with both methodology and planning issues and the preparation of tax reporting.
Depending on the organizational structure of the enterprise and the geographical dispersion of its divisions (subsidiaries), the structure of the tax department can be modified both in the direction of further detail (for example, by separating tax planning functions into a separate division of the tax department) and significant simplification (for example, by combining the functions of developing tax methodology and preparing tax reporting).
Rice. 1.
When organizing interaction between the tax departments of an organization and its branches, it is necessary to resolve the issue of distribution of powers, as well as develop an approach to unify positions on tax issues. In particular, for this you need to determine:
a list of tax situations falling under the jurisdiction of the “center” and divisions;
tax accounting policy;
the procedure for coordinating the interaction of departments with tax authorities.
The centralized tax model is more suitable for organizations operating in the regions through branches. In this case, most of the main taxes are assessed by the head office for the enterprise as a whole, using data provided by the regions. Therefore, in the process of preparing tax reporting, the head office can control the tax assessment methods used in the regions. This model is also applicable for a group of organizations. However, Russian tax legislation treats each company as a separate taxpayer, therefore, each company prepares its own reports. Therefore, to ensure a unified tax strategy, it is necessary to develop additional procedures for monitoring the correctness of tax calculations by group companies.
Using a decentralized model is less focused on accomplishing the tasks facing the group as a whole. In addition, this model makes it difficult for the head office to control the activities of regional divisions. At the same time, decentralization of tax management may be acceptable if there are strong tax departments in regional companies, as well as during the period of regional expansion of the company (holding) or at the stage of establishing interactions between the parent and regional organizations.
In practice, most organizations use a combined option, in which some functions are centralized, while other functions are delegated locally.
To ensure the fulfillment of the goals and objectives set for the tax department, it is necessary to develop an effective system for monitoring their implementation. To do this, it is necessary to formulate criteria for the effectiveness of tax management. Such criteria can be used, for example, the following: the level of the effective tax rate for income tax and other taxes; the total level of additional tax charges and sanctions recognized by the company based on the results of tax audits for the year (assessment of the degree of completion of this task is possible as tax periods are “covered” by tax audits); the total level of tax risks, the probability of which was assessed by auditors as “very high” and “high” based on the results of an audit of the company’s activities for the year.
The criteria for the work of the tax department may also include the execution of current tasks, such as the development and/or implementation of a unified tax accounting system for income tax for the holding’s subsidiaries, ensuring the timely submission of the company’s tax reports to the tax authorities, or reducing the time for preparing a tax return for various taxes by introducing more efficient procedures for preparing and verifying tax returns.
The main criteria for tax control may be
possible tax sanctions during audits. This does not refer to data from tax acts and decisions, but to the final amounts of sanctions imposed as a result of legal proceedings.
tax budget. The chief accountant is responsible for the execution of this budget. He controls its implementation during the month and can adjust the amount of taxes paid within the budget. Budgetary deviations are analyzed together with the internal audit service, as a result of which certain recommendations are developed for accounting and management of organizations E. S. Vilkova, M. V. Romanovsky. Tax planning St. Petersburg: Peter, 2008 - P. 441.
Thumbnails Document Outline Attachments
Previous Next
Presentation Mode Open Print Download Go to First Page Go to Last Page Rotate Clockwise Rotate Counterclockwise Enable hand tool More Information Less Information
Enter the password to open this PDF file:
Cancel OK
File name:
File size:
Title:
Subject:
Keywords:
Creation Date:
Modification Date:
Creator:
PDF Producer:
PDF Version:
Page Count:
Close
Preparing document for printing...
Federal State Autonomous Educational Institution of Higher Education "SIBERIAN FEDERAL UNIVERSITY" Trade and Economic Institute Department of Accounting, Analysis and Audit BACHELOR'S THESIS 03/38/01 "Economics" profile 03/38/01/04/07 "Finance and credit (organizational finance)" "Tax burden management organization" Scientific supervisor, Ph.D., associate professor M.I. Migunova Graduate A.K. Tersky
CONTENTS Introduction………………………………………………………………………………...3 1 Theoretical foundations for managing the tax burden of an organization……….5 1.1 Tax burden : concept, essence, role and significance of the indicator……………………………………………………….………………5 1.2 Approaches to managing the tax burden………… ………………..…15 1.3 Methods for optimizing and calculating the tax burden……….….……......23 2 Analysis of the tax obligations of JSC Krasnoyarsknefteprodukt…………...32 2.1 Organizational and economic characteristics……………………..… 32 2.2 Analysis of the formation of tax obligations, structure and dynamics of tax payments of JSC “Krasnoyarsknefteprodukt”………………...………..…45 2.3 Analysis of the tax burden and tax efficiency indicators of JSC Krasnoyarsknefteprodukt………………………...…...57 3 Measures to improve the management of the tax burden of JSC Krasnoyarsknefteprodukt…………………………………………………… ………………….…57 3.1 Measures to improve the management of the tax burden of JSC “Krasnoyarsknefteprodukt”……………………………….………………..…57 3.2 Assessment of economic efficiency from implementation measures to improve the management of the tax burden of JSC "Krasnoyarsknefteprodukt"…………………………………………………………..….…..71 Conclusion……………………………………………………… ………………………………….……76 List of sources used…………………………………….…….….78 2
INTRODUCTION Both in Russia and in any other state it is impossible to do without taxes. Taxes are necessary to ensure the economic activity of the state. There is no doubt that taxes also play an important role for organizations, namely the assessment of their obligations, which makes it possible to determine how burdensome the tax system is for the organization today and what part of the resources of an economic entity is attracted by payments to the budget, that is, to determine the tax burden of the enterprise. However, it is difficult to imagine the economic growth of business entities without a competent system for managing their financial resources and the sources of their formation. It is worth noting that taxes are one of the main external restrictions on an organization’s financial resources and return on equity. Typically in Russia, tax optimization has not been fully taken into account in the financial management system. However, the success or failure in the activities of a business entity is largely determined by optimized taxation. Tax optimization manifests itself not only in the management of the organization’s financial resources, but also in the optimization of financial results. It should be noted that the goal of the economic activity of any business unit is considered to be profit maximization. As a result, it is worth noting that organizations and entrepreneurs often try to reduce the tax burden on businesses, but under certain circumstances, tax reduction becomes illegal, as a result of which the taxpayer may face both a fine and criminal liability. The tax system should not reduce taxpayer incentives for entrepreneurial activity. It must provide for the reasonable needs of the state, withdrawing from the taxpayer, as a rule, no more than a third of his income. 3
In conditions of economic instability, it becomes more difficult for enterprises to pay taxes, they feel the severity of the impact of the tax burden more acutely, and therefore the chosen topic of work “Tax Burden Management” is relevant. The purpose of the diploma tax work is to improve JSC Krasnoyarsknefteproduct management, which will allow the enterprise under study to function more efficiently. To achieve this goal, the following tasks were solved in the thesis: - consider the theoretical aspects of the tax burden in the organization’s management system; - explore approaches to managing the tax burden of an organization; - study the functions and methods of calculating the tax burden; - analyze the organizational and economic characteristics of Krasnoyarsknefteproduct JSC; - analyze the tax burden and tax efficiency indicators of the organization; - assess the effectiveness of tax burden management; - give recommendations for improving tax burden management. Thesis "Krasnoyarsknefteproduct". completed This organization of materials operates as a joint-stock company in the city of Krasnoyarsk and is the largest distribution network of oil depots and gas stations in the Krasnoyarsk Territory. The subject of the study is economic relations related to managing the tax burden of Krasnoyarsknefteproduct JSC. The methodological basis consists of economic-statistical, economic-mathematical and regulatory methods. The theoretical basis of the work is the work of domestic authors, such as: M. N. Kreinina, E. A. Kirova, M. I. Litvin, T. K. Ostrovenko, E. S. Vilkova, O. F. Pasko, A. V. . Ignatova, T. F. Yutkina; regulatory 4
documentation; official instructional and methodological materials; publications in periodicals; information system "Consultant Plus". The information base was the statistical and accounting reports of the enterprise JSC Krasnoyarsknefteproduct. The practical significance of the work is qualified by the results of the tax problems found and the proposed ways of improvement through tax optimization for the management of Krasnoyarsknefteproduct JSC. The work consists of an introduction, three chapters, a conclusion, a list of references and applications. The total volume of work was 84 pages excluding appendices. The work is illustrated with 36 tables and 8 drawings. The bibliography includes 40 sources. 5
1 Theoretical foundations for managing the tax burden of an organization 1.1 Tax burden: concept, essence, role and significance of the indicator Assessment of the tax burden is one of the main aspects of the functioning of the tax system. A properly constructed taxation system leads to the efficient functioning of the entire economy. There is no unity among the authors in defining the concept of “tax burden” due to the imperfection of the conceptual apparatus. With the definition of “tax burden”, concepts such as “tax burden”, “severity of taxation”, “tax pressure”, “tax withdrawal”, “tax pressure” are often used. In the literature, the concepts of “tax burden” and “tax burden” are most often used to determine the impact of taxes. Many works of modern economists are devoted to the definition and calculation of the tax burden both at the micro and macro levels. At the macroeconomic level, the tax burden is determined by the ratio of the total amount of tax revenues to the budget to the volume of gross domestic product. Also at the macroeconomic level, the tax burden is interpreted as “a set of government instruments that allow it to specify the overall budget decision on the total volume of revenues that provide the necessary expenses of the public sector” and is determined by the ratio of the amount of all taxes and fees received by the country’s budget to the gross domestic product. At the microeconomic level, the tax burden indicator reflects the share of the total income of the tax payer withdrawn in 6
budget system. At the same time, it is worth noting that there is no single approach to determining the tax burden at the microeconomic level. In order to more fully disclose the definition of “tax burden,” we will consider its meaning based on the point of view of various authors. The results are presented in Table 1. Table 1 - Analysis of the concept of tax burden in the works of various academic economists Author E. V. Chipurenko Source Tax burden of an enterprise: analysis, calculation, management. Supplement to the journal Tax Bulletin / Chipurenko E.V. - 2008. A. N. Tsygichko Normalization of tax “Part of the total financial burden / Tsygichko A.N. - load limiting resources Moscow: ITRK, 2002. expansion and modernization of enterprises” Balatsky E.V. Lafferov “The level of maximum permissible effects and financial criteria for the amount of tax withdrawals from economic activities // organizations in the state budget” World economy and international relations. A. Laffer Definition “Quantitative and qualitative characteristics of the influence of mandatory payments to the budget system of the Russian Federation on the financial position of taxpayer enterprises” I. A. Mayburov Taxes and taxation “Defined as a share of income, / Mayburov I.A. – Moscow: paid to the state in the form of Unity - given, 2008. taxes and payments of a tax nature” O. S. Salkova Methods for assessing the level of taxation of unprofitable enterprises / Salkova O.S. // Finance. - 2005. T. Zh Ostrovenko Tax burden on “Assessing the impact of tax enterprises: generalizing and payments on the financial condition of private indicators: educational enterprises” manual / T.Zh. Ostrovenko, 2011. – 269 p. 7 “Tax burden as a tool for monitoring and planning many parameters of financial and economic activity”
End of table 1 Author S. A. Pelikh, D. Ch. Tabala Source Taxation as a factor in increasing the competitiveness of enterprises / S. A. Pelikh, D. Ch. Tabala / Finance. – 2004. No. 11. – P. 73-76. V. Kornus, V. Kvasov Assessment of the tax burden at the enterprise level / V. Kornus, V. Kvasov, A. Ponomarev // Economist. - 2007. pp. 47 – 49. A. Sokolovskaya Theoretical foundations for determining the tax burden and level of taxation of the economy / A. Sokolovskaya. A. B. Paskachev, Analysis and planning F. K. Sadygov of tax revenues: theory and practice / F. K. Sadigov et al. Definition “The ratio of the amount of taxes and deductions, the real payer of which is the enterprise, to the amount of profit of the enterprise. The real payer of the tax is the entity that is the owner of the object of taxation, when the obligation to pay tax arises from the very fact of the existence or emergence of the object of taxation and the user of the object of taxation, when the obligation to pay tax arises only when the object is in certain conditions of use" "Part of business income, which is withdrawn by the state from a business entity through a system of taxes and fees to budgets of various levels" "The effect of taxes on the economy as a whole and on individual payers associated with economic restrictions that arise as a result of paying taxes and the diversion of funds from other important areas of their use" “The maximum possible amount of mobilization of the organization’s financial resources, which through the taxation system and in accordance with the current legislation must go to the appropriate budgets” It should be emphasized that at the legislative level the tax burden is mentioned in the Letter of the Federal Tax Service of Russia “On the work of the commissions of tax authorities on the legalization of the tax base” dated March 21, 2017 No. ED-4-15/5183. This letter contains formulas for calculating the tax burden for tax regimes and 8
some specific taxes. Also, the Order of the Federal Tax Service of Russia “On approval of the Concept of the planning system for on-site tax audits” dated May 30, 2007 No. MM-3-06/333 reflects the indicators of the total tax burden by economic sector. Based on the calculation formulas contained in both documents, it should be assumed that the tax burden is the ratio of the amount of taxes and fees to the proceeds from the sale of products and goods, as well as revenues associated with the performance of work and the provision of services. Thus, if we generalize the concept of “tax burden,” we can characterize it as a generalized quantitative and qualitative characteristic of the impact of mandatory payments to the budget on the financial condition of organizations, businesses and entities as requirements for state regular funds, payments that are considered as a set of state instruments. Researcher I. Seliverstova, considering the tax burden on an economic entity, identifies 4 areas, presented in Figure 1, through which the tax burden is realized. Figure 1 – Directions for implementing the tax burden 9
It is difficult to disagree with this approach, because in the course of their activities, organizations feel the influence of each of the listed areas. It is worth noting that the strength of their influence will differ depending on the taxation system that the organization has chosen: the traditional system or special tax regimes, which also provide choice and opportunities to reduce the tax burden. It is no coincidence that many works by economists are devoted to the study of the tax burden, since optimization of the tax burden plays an important role in creating and improving the state tax system. Figure 2 shows the main areas of application of the tax burden indicator. Figure 2 - Main areas of application of the tax burden indicator The role and significance of the tax burden indicator is as follows: - when new taxes are introduced and old ones are changed by reducing or increasing tax rates and tax benefits, the state must determine where the maximum permissible levels of pressure on the national economy are located , beyond the borders of which negative economic 10
processes. It is also worth noting that the tax burden indicator can be used to forecast budget revenues; - the tax burden indicator serves to study the influence of the tax system on the development of the state’s social policy. Studying the fairness of taxation regarding living citizens of the state, the burden of taxation between different social groups, allows the state to more fairly distribute the burden of taxation between different social groups in order to stabilize the socio-economic situation in the country; - the tax burden indicator is used as an indicator of how organizations will behave. To a greater extent, the tax burden determines how business entities decide to invest their own financial resources in the development of one or another production, in one or another sector of the economy. The financial position of each specific organization also depends on this indicator; - from the point of view of the organization, the tax burden indicator serves to understand how the tax service treats their activities and payment of taxes. Calculating the tax burden indicator will help warn against conducting an audit in the organization; - the tax burden indicator determines the tax burden for the next period, which can serve as the basis for making informed management decisions in the future. Thus, we can conclude that the calculation of the tax burden can be carried out at two levels: macro level and micro level. The macro level involves calculating the burden of the tax burden on the economy. The tax burden on the population is assessed, on the one hand, as the level of taxation of an individual employee, and on the other hand, as the level of taxation of the population as a whole. Note that the tax burden is 11
The population as a whole is determined by the ratio of all taxes paid per person to the average per capita income of the population. Naturally, for each specific taxpayer, both a legal entity and an individual, it is not important what the degree of tax burden on the economy as a whole is, since he pays taxes from his own income, and therefore there are specific indicators for him that characterize the level of the tax burden. The micro level determines the tax burden on specific business entities. It is important to understand that the main goal is to level out the interests of the state and the organization. Considering the tax burden as an independent economic category, it is important to determine the internal basis of this indicator and its formation. A. S. Borodina defines the essence of the tax burden as a set of indicators characterizing the impact of mandatory tax payments on the financial position of a business entity and identifies factors that influence the size of the tax burden of a business entity: - elements of both accounting and contractual policies for tax purposes; - exemptions and benefits, in particular from the performance of taxpayer duties; - main directions of development of tax, social, budget and investment policies of the state, which directly affects the elements of taxes; - obtaining an investment tax credit, budget loans, installment plans and deferments on taxes and fees. M. Romanovsky, considering the tax burden as part of the tax planning of a business entity 12, argues that it is
an integral part of management in financial and economic activities and is the process of using acceptable, legal tax methods and methods to increase the financial condition of an object in conditions of limited resources. In any organization, not a single business plan, not a single management decision is made without taking into account the current tax system, and this task is solved by the divisions that are responsible for tax consulting and tax management. Through the influence of taxes on the management of income, expenses and final results, the tax burden interconnectedly has an impact on other areas of the organization’s financial activities. Considering the fact that the tax aspect is present in any segment of financial management of business entities, the tax burden, being part of financial management, as an element of tax planning, occupies a certain place in it. E. A. Gracheva argues that tax planning is a way to minimize the tax burden, which includes the development of complex systems that reduce the tax burden on a business entity. It is difficult to disagree with E. A. Gracheva, because this statement objectively reveals the connection between the concepts of tax burden and tax planning. V. A. Bunko understands tax planning as the activity of the taxpayer aimed at reducing taxes and the main goal is to obtain tax savings, reduce the level of tax burden while complying with the law. V. A. Bunko notes that the greater the impact of taxes on the financial and economic indicators of the activities of business entities, the greater the influence the tax component acquires in the management of the organization. Also, it is worth noting that a change in the tax burden is a consequence that occurs under the influence of tax methods
planning. Tax planning is achieved using special methods, which include a set of measures aimed at reducing the tax burden. Table 2 discusses the main tax planning methods aimed at reducing the tax burden. Table 2 - Basic tax planning methods aimed at reducing the tax burden Internal planning External planning Selecting an accounting policy Replacing a tax entity Using tax credits Changing the type of activity Using special regimes Replacing tax jurisdiction Undoubtedly, internal planning methods are less risky, since they can be used without changing its type of activity and place of registration of the business entity, which cannot be said about external methods that can entail global consequences for the organization, therefore their use and application is quite limited. When applying certain methods and techniques of tax planning, the taxpayer must adhere to the basic principles that will allow him to achieve his goals with minimal effort and without violating the law. The principles of tax planning can be divided into several main groups: - the principle of legality of compliance with all tax regulations when calculating and paying tax payments. It is this principle that is fundamental; it allows tax planning to be distanced from accusations of tax evasion; - the principle of efficiency implies timely tax planning. This means that the company’s approved accounting and tax policies must be reviewed in a timely manner to quickly respond to changes in tax legislation, allowing 14
reduce the burden of paying taxes. Also, changes must be made in a timely manner in the event of a new line of activity, expansion or other reformatting of the business; - the principle of optimality, which involves the use of mechanisms that would lead to a reduction in the tax burden without compromising the business goals and interests of the owners of the enterprise. Businessmen will need to achieve a balance between the size of the tax burden and the amount of expected profit that could be used to expand the business. Analysts need to calculate in advance what economic effect should be expected from the implementation of a particular tax planning method, whether the costs of its implementation will cover all the expected profitability both in the short and long term. It is necessary to timely calculate whether a reduction in one tax will lead to an increase in other mandatory payments; - the principle of validity assumes that the taxpayer has prepared in advance the necessary arguments to explain to tax inspectors and defend his position in court in the event of the use of unpopular or controversial tax planning methods; - the principle of complexity, which means that tax planning takes into account not only the norms of tax legislation, but also other legal branches, especially civil legislation; - the principle of professionalism, which says that it is necessary to attract qualified specialists to such activities, which means competent preparation of primary documents, contracts, registers, reports; - the principle of confidentiality, which means that the taxpayer should not disclose to outsiders the tax planning methods used at the enterprise. Thus, based on the above material, we come to the conclusion that the tax burden seems to be one of the most important 15
evaluation criteria for the state and is an integral part of management in the financial and economic activities of any enterprise. By tax burden we mean a set of indicators characterizing the impact of mandatory tax payments on the financial position of a business entity. 1.2 Approaches to managing the tax burden of an enterprise The main task of an economic entity within the framework of managing tax processes is to find the best approach to managing the tax burden. Figure 3 reflects theoretical approaches to managing the tax burden of business entities. Figure 3 – Theoretical approaches to managing the tax burden of business entities The first approach to managing the tax burden of an organization involves minimizing this indicator. The following methods are distinguished: - tax evasion; - minimizing tax payments. Note that tax evasion is an illegal reduction of tax payment obligations based on
conscious criminal use of methods of hiding income and property from tax authorities, creating fictitious expenses, as well as deliberate (deliberate) distortion of accounting and tax reporting. The main difference between tax optimization and tax evasion is compliance with the law, and it is important to realize how thin this line is. Therefore, it is important to know tax laws to avoid problems in the future. Figure 4 shows crimes that are associated with tax evasion. Figure 4 – Tax crimes provided for by Russian legislation The main signs of tax evasion are: - concealment of revenue or income; - unlawful use of fixed assets and reserves of the enterprise; - concealment of funds through the use of personal accounts or current accounts of friendly organizations; 17
Cost manipulation; - abuse for personal interests; - formal increase in the number of employees; - illegal creation of new organizations; - illegal conduct of activities. It is worth noting that inept attempts to minimize taxation can lead to serious financial and legal consequences. Practice shows that most organizations that set the goal of tax optimization only to reduce the tax burden are sooner or later subject to on-site inspections by tax or law enforcement agencies. An on-site tax audit is a process that is built on the selection of taxpayers to carry out control based on publicly available criteria for the risk of committing a tax offense. A taxpayer who meets these criteria is more likely to be included in the on-site tax audit plan. It is worth noting that the main criterion for such a check is a low tax burden. There is an approach to managing the tax burden, which consists of deliberately inflating the tax burden, and some enterprises use this approach. We conclude that in practice, minimum payments are not always optimal. For example, an organization that stands out in comparison to others by paying too little risks attracting additional scrutiny, which may entail additional costs. Managing the tax burden is necessary not only to save costs through tax payments to the budgets of the budget system of the Russian Federation, but also to ensure the stable operation of organizations. One of the main approaches to managing the tax burden involves optimizing the taxation of the expected tax burden. reduction 18 Under optimization of tax obligations
through targeted lawful actions, which include the use of benefits, tax exemptions and other legal techniques and methods. Such lawful actions include the qualified organization of tax payment matters. Qualified organization of tax payment cases allows you to eliminate or reduce cases of unjustified overpayment of taxes or the accrual of tax penalties. Tax optimization should ensure both the efficient use of one’s financial resources and the optimization of tax payments at an acceptable level of tax risk. Do not forget that tax optimization should also ensure highly profitable use of equity capital. Tax evasion and direct reduction of tax payments have nothing to do with tax optimization. Practice shows that tax optimization manifests itself in reducing the amount of taxable profit and effective planning of tax payments, taking into account the specifics of the organization’s activities. Note that minimization and optimization are not the same thing. Tax minimization is expressed in the maximum reduction of all taxes, and tax optimization is defined as a process that is associated with achieving certain proportions of all aspects of the enterprise’s activities as a whole. Managing the tax burden in a crisis situation in the country was determined not only by the possibility of saving costs through tax payments, but also by the prospects for the stable operation of organizations. Typically, if the tax burden is from 20 to 35%, then the need for tax planning is urgent. In order for tax planning to take place effectively, you need to introduce a staff unit that will be entrusted with these functions. In large companies, in addition to one specialist, there are entire departments that control all tax obligations. Typically, for the implementation of large projects, tax planning specialists are involved in outsourcing 19
basis. If the tax burden exceeds 40%, then the organization needs to pay special attention to tax planning, based on the fact that the company may become uncompetitive and, in the worst case, go bankrupt. Based on this situation, tax planning should be given great importance, namely, for medium and large organizations it is preferable to create a tax planning department. The Russian Federation has a three-tier tax system for taxpayers, which includes federal, regional and local taxes and fees. Let us characterize the types of taxes that enterprises pay. Table 3 – Classification of taxes in the Russian Federation Federal taxes and fees (Article 13 of the Tax Code of the Russian Federation) Regional taxes and fees (Article 14 of the Tax Code of the Russian Federation) Local taxes (Article 15 of the Tax Code of the Russian Federation) - value added tax; - excise taxes; - tax on personal income; - corporate income tax; - mineral extraction tax; - water tax; - fees for the use of objects of the animal world and for the use of objects of aquatic biological resources; - National tax. - tax on property of organizations; - gambling tax; - transport tax. - land tax; - tax on property of individuals; - trade fee. In practice, each individual organization does not pay all of the above taxes and fees to the budget; this is the individuality of the tax field. This is due to the fact that taxes must be calculated and paid by an enterprise only if an object of taxation arises, which is very specific to each tax. In the absence of an object, the enterprise is liable. 20 tax does not arise
Thus, the tax field of an organization determines the tax framework within which the organization can carry out its activities, formulate financial policies, make management decisions, and regulate the level of taxation. It is important for business entities to assess how much taxes they will have to pay, for example, by expanding their activities or using the tax regime of the Tax Code of the Russian Federation. Special tax regimes in the tax system of the Russian Federation include five taxation systems: - taxation system for agricultural producers - Chapter 26.1 of the Tax Code of the Russian Federation; - simplified taxation system - Chapter 26.2 of the Tax Code of the Russian Federation; - taxation system in the form of a single tax on imputed income for certain types of activities - Chapter 26.3 of the Tax Code of the Russian Federation; - taxation system for the implementation of production sharing agreements - Chapter 26.4 of the Tax Code of the Russian Federation; - patent taxation system - Chapter 26.5 of the Tax Code of the Russian Federation. If we talk about the taxation system, then you need to understand its main elements. According to Art. 17 of the Tax Code of the Russian Federation, a tax is considered established only if the taxpayers and elements of taxation are determined, namely: - the object of taxation; - the tax base; - taxable period; - tax rate; - tax calculation procedure; - procedure and deadlines for tax payment. A comparison of the main elements of various taxation systems is presented in Table 4. 21
Table 4 - Comparative characteristics of the elements of special tax regimes applied in the Russian Federation Tax regime General taxation regime Tax Income tax Organizational profit Tax organization movable and immovable property VAT Simplified taxation system UTII Unified Agricultural Tax Patent system Object of taxation Single tax paid in connection with the application Simplified tax system Unified tax on imputed income Unified agricultural tax Organizational profit tax Rate 20% Not more than 2.2 Sales of goods 0%, 10%, 18% Income (clause 1 of Article 346.14 of the Tax Code of the Russian Federation) 6% (Article 346.20 of the Tax Code RF) Income reduced by the amount of expenses (Article 346.14 of the Tax Code of the Russian Federation) 15% (Article 346.20 of the Tax Code of the Russian Federation) Imputed income (clause 1 of Article 346.29 of the Tax Code of the Russian Federation) 15% (Article 346.31 of the Tax Code of the Russian Federation) Income reduced by the amount expenses (Article 346.4 of the Tax Code of the Russian Federation) 6% (Article 346.8 of the Tax Code of the Russian Federation) Potentially receivable annual income (Article 346.47 of the Tax Code of the Russian Federation) 22 6% (Article 346.50 of the Tax Code of the Russian Federation) Tax base Monetary expression of profit (Article 274 of the Tax Code ) Average annual value of property (Art. 375 of the Tax Code of the Russian Federation) Depends on the specifics of implementation (Article 153 of the Tax Code of the Russian Federation) Monetary expression of income reduced by the amount of expenses (clause 2 of Article 346.18 of the Tax Code of the Russian Federation) Amount of imputed income (clause 2, 3 and clause 10 of Article 346.29 of the Tax Code RF) Monetary expression of income reduced by the amount of expenses (Article 346.6 of the Tax Code of the Russian Federation) Monetary expression of possible income (Article 346.48 of the Tax Code of the Russian Federation)
This table allows you to visualize the differences in the main parameters for comparing special tax regimes. Each taxpayer independently chooses a tax regime and calculates the economic effect of this choice. The possibility of choosing a tax regime is influenced by many criteria, including: - type of activity; - organizational and legal form; - amount of workers; - the amount of income received; - regional features of tax regimes; - the cost of fixed assets on the balance sheet of the enterprise; - circle of main clients and consumers; - export-import activities; - preferential tax rate; - regularity and uniformity of income generation; - the ability to properly document expenses. In the analysis of the activities of any organization, an important role is played by the assessment of tax liabilities, which makes it possible to determine the burdensomeness of existing tax systems for an economic entity and the share of resources that attract payments to the budget, that is, to determine the tax burden of the enterprise. Therefore, it is so important to analyze all the components that form the information base for calculating the tax burden, that is, the tax payments of the organization. The financial management of an organization needs to formulate the best decisions in production and economic activities, which lead to a reduction in the tax burden. Correct optimization of taxation ensures a stable position of the organization in the market, allowing it to avoid large business losses. 23 in the process of economic
The legislation of the Russian Federation provides organizations with various tools that allow them to balance the tax burden of an enterprise when the solvency of buyers decreases. Such instruments may be: - contractual and accounting policies; - creation of reserves for doubtful debts; - assignment of the right of claim; - novation of debt; - reorganization of the company and creation of a separate legal entity operating using the simplified taxation system (STS); - deferment, installment plan, investment tax credit; - tax holidays. Thus, the tax and civil legislation of the Russian Federation provides some opportunities to minimize the negative consequences of non-payments and offers methods for managing the tax burden of an enterprise. 1.3 Methods for optimization and calculation of the tax burden Tax optimization methods can affect both legal entities and individuals. When analyzing the tax burden, a significant factor is not only the quantity, but also the structure of taxes paid. There are several methods for optimizing the tax burden for organizations. One of the methods is the relationship replacement method, which assumes that the same economic goal can be achieved in different ways. As a rule, the same economic goal (purchase of property, receipt of income, etc.) can be achieved by several
alternative ways. The current legislation practically does not limit a business entity in choosing the form and individual terms of a transaction, choosing a counterparty, etc. An individual has the right to independently choose any of the acceptable options, taking into account the efficiency of the operation, both in economic terms and from a tax point of view. This method consists of fulfilling two criteria: - replacing an operation with more stringent taxation with another operation with a preferential tax regime; - achieving the goal that existed before the replacement operation or achieving the goal as close as possible to it. An example is the replacement of the operation of free transfer (donation) of goods from one entrepreneur to another. The next method involves relationship separation, which relies on the relationship replacement method. This method makes it possible to reduce the total amount of tax liabilities and is based on replacing a certain part of operations, or one operation can be replaced by several others. An example would be a contract, when the performance of work from the contractor’s materials can be replaced by two contracts, such as: a contract for the provision of services and a contract for the sale and purchase of materials. The method of delegating taxes to a satellite enterprise involves transferring the object of taxation to an alternative business entity. The taxpayer, most often, shifts various “tax-intensive” activities to other organizations that are under his control. An economic entity on a single tax, manufactures toy products and a partial entrepreneur sells their products on a single tax, through remaining another private controlled business entity, thereby reducing the amount of income so as not to 25
exceed the maximum established limit. Otherwise, he will have to either switch to another tax system. The preferential entrepreneur method is one of the most common methods of tax optimization, which consists of transferring taxable objects. One of the widely used methods of tax optimization consists in transferring taxable objects to a preferential tax regime, which is associated with the special tax status of certain business entities. An example is the tax status of small businesses that use a simplified taxation system; agricultural producers, etc. An example is the sale of products with the help of an economic entity that is under a special tax regime. The method of using accounting policies is based on the interdependence of tax and accounting and lies in the fact that by changing accounting policies the size of tax bases can be changed. This method may only be relevant for entrepreneurs on the general taxation system. The method of taking over a loss-making company is that a company that has stable profits takes over an unprofitable company. As a result of this merger, all losses in full are transferred to the legal successor and reduce his taxable profit. Moreover, in accordance with Article 283 of the Tax Code of the Russian Federation, these losses can be carried forward to subsequent tax periods. The method of acquiring an unprofitable company is especially relevant, given the fight of the Federal Tax Service against unprofitable companies. Like any other reorganization, the merger must have purely business reasons: obtaining new markets or raw materials; creating a new line of business or even eliminating an inconvenient competitor. The business 26 version of the goal should be justified in
special business plan. In addition, the goals and objectives of the reorganization can be mentioned in the protocols of the founders, drawn up when making a decision on reorganization and subsequent registration of changes to the constituent documents. The method of replacing tax jurisdiction is to register a business entity in a territory that provides preferential taxation. The amount of tax deductions is different when each region of the country is given the rights to formulate local legislation. Hence the differences in the amount of tax deductions. Developing a company development strategy involves the possible organization of branches or branches in external zones with a minimal tax burden on the business. By analyzing the tax burden, the issue of definition and approach to calculating the tax burden is resolved. Practice shows that the justification and correct choice of a system of indicators for determining the tax burden and methods for their calculation play an important role in the company. As mentioned earlier, calculating the tax burden has an important goal for a business entity - forecasting the tax burden for the future period. For large companies, calculating the tax burden in future periods is essential. It is important to assess how much taxes an organization will have to pay, for example, by expanding its activities. Additionally, you can calculate the share of taxes in revenue, profit, and salary taxes in the payroll fund. All this should help the organization in tax planning of contributions to the budget. At the same time, it is also important to provide for various tax risks that affect the increase in the tax burden. The tax burden is assessed using various methods and approaches. Let's look at them in more detail in Table 5. 27
Table 5 - Methods for determining the tax burden Author of the methodology: Ministry of Finance of Russia Formula NNs = Ntotal ·100 Total where NNs is the total tax burden; Ntot – total amount of taxes; Total – the total amount of revenue determined according to Goskomstat data. M. N. Kreinina NN V Pch Wed ·100 V Wed where NN is the tax burden; B – sales revenue; Ср – production costs of sold products excluding taxes; Pch is the actual profit remaining at the disposal of the enterprise. M. I. Litvin DS = JSC + (Personal Fund + VP) + NP + PR, NN = (ST /TV) 100%, where NN is the tax burden; ST – amount of taxes and mandatory payments; TV – size of the source of funds for paying taxes. Advantages of the method Disadvantages of the method Simplicity of average calculation. and This methodology does not determine the impact of changes in the tax structure on the tax burden indicator; Determines only the tax intensity of products, works or services; does not give a real picture of the tax burden borne by the taxpayer; does not take into account changes in the legislation on taxes and fees, thus cannot reflect directions for improving taxation. This methodology underestimates the measure of the influence of indirect real taxes on the financial state of the organization; in its analysis of the impact of calculations, direct personal income tax taxes are not used, and in general it cannot be used on the financial state of the unprofitable activity of the enterprise. enterprises. Allows you to assess the optimal level of tax burden for a particular industry, taking into account the share of labor costs and material costs. 28 Disadvantages include the inclusion of personal income tax in the calculations. It is worth noting that this approach cannot be called correct, since the final source of payment of all tax payments is the added value created by the enterprise.
Continuation of table 5 Author of the methodology Formula A. DS Kadushin, Ko = B, N. Mikhailov AM Kam = , DS Notot) NA NN = PE () NA (E. A. Kirova where NN is the tax burden; Ntot is the amount of taxes in the aggregate volume; NA - net assets of the enterprise; NP - net profit; V - revenue; VSS = OT + SO + NP, Dn = O. F. Pasko NP SO · 100 VSS where - relative tax burden; ВС - newly created value; СО - tax payments; П - profit of the organization; - tax payments; CB - borrowed funds. Advantages of the method Disadvantages of the method This method allows you to evaluate the tax burden as a function of the type of production, which changes depending on fluctuations in the costs of material resources, labor or depreciation; it allows you to analyze the structural composition of tax payments in relation to; added value. The methodology does not take into account the impact of taxes such as property tax, transport tax, payments for the use of natural resources, land tax; the indicator of the enterprise's net profit depends not only on the amount of tax payments, therefore, the indicator of the tax burden calculated using the above methodology does not allow us to analyze the tax burden of enterprises in different business conditions, in particular, those with different levels of profitability. The amount of indirect taxes to be transferred is included in tax payments when calculating. When using this method, it is not possible to qualitatively predict changes in the indicator depending on changes in the number of taxes, their rates and benefits. Determines the share of taxes in the total amount of money received. It is not objective, because the funds actually received from the sale of products in the current period are not known. 29
End of table 5 Author of the methodology T.K. Ostrovenko Formula NN = Advantages of the methodology Allows you to calculate the tax burden with varying degrees of detail and depending on the assigned management task. When calculating indicators, information reflected in the reporting of economic entities is used. This can shorten the settlement process. NI Source where NI – tax costs; TN – tax burden. Analysis of the methods carried out Disadvantages of the method Impossibility of comparing the tax burden of enterprises in different economic conditions, since the amount of equity capital, balance sheet currency, profit before tax in addition to taxes is influenced by a number of other factors, in particular the size of staff wages, the level of markup per realized products. calculating the tax burden of an economic entity shows that, despite differences in approaches, the data obtained by researchers as a result of applying the considered methods can be used to carry out tax planning and tax optimization activities by both taxpayers and the state. Specialists who calculate the tax burden for a specific economic entity can recommend an integrated approach to determining the tax burden and the use of all the methods discussed above. This approach will allow not only to more accurately assess the tax obligations of an economic entity, but also to understand where optimization of taxation should begin in each specific case, which tax obligations are the “bottleneck” in a given enterprise and which of the accounting objects is most “overloaded” with them . thirty
In addition to these calculation methods, there are other proprietary approaches to determining the tax burden of an enterprise. These are the calculation models of E. S. Vilkova, A. V. Ignatov, T. F. Yutkina and other authors. However, these methods are complex and voluminous in calculations, and are based on the models we have considered. The difference in methods for determining the tax burden is manifested in the interpretation of such key points as the number of taxes that are included in the calculation, as well as the definition of the integral indicator with which the amount of taxes is correlated. Controversial among the methods are such questions as whether to include personal income tax in the amount of taxes, given that the economic entity is a tax agent, whether it is necessary to take into account indirect taxes, based on their transfer to the final consumer, and with what indicator to compare the taxes paid (profit of the economic entity, added or newly created value, sales revenue). Most authors are of the opinion that in order to determine the tax burden, it is necessary to correlate tax payments with added value, because It is believed that the added value created at a particular enterprise is the source of income and, accordingly, the source of payment of all taxes. In addition, revenue from product sales, production volume, net profit, financial resources, average annual balance sheet currency, and profit before tax are taken as performance indicators. Existing methods for determining the tax burden, due to the peculiarities of calculating the tax burden, are capable of comprehensively assessing the level of taxation of an enterprise applying the general taxation regime, but cannot be used as an assessment of the tax burden when the enterprise applies a special tax regime. Within the framework of special taxation regimes, a simplified taxation system and a taxation system for 31
agricultural producers (Agricultural Producers). Both regimes are largely similar in terms of the mechanism for calculating the single tax. It is worth noting that in the letter of the Federal Tax Service of Russia dated March 21, 2017 No. ED-4-15/5183, there are formulas for calculating the tax burden for special tax regimes, which are the percentage of the actually accrued tax in the tax base for this tax. Taxpayers who intend to use this indicator to independently determine the risk of an on-site tax audit are recommended to determine their total tax burden and compare it with the same indicator for 2016 for their main type of activity from Appendix No. 3 to Order No. MM-3-06/333 . Thus, each organization chooses its own method for calculating the tax burden. To assess the most optimal amount of the tax burden, it is advisable to calculate the amount of the tax burden using various methods. Calculation of the tax burden will help to assess the impact of tax payments on the financial condition of the enterprise. 32
2 Analysis of tax obligations of JSC "Krasnoyarsknefteproduct" 2.1 Organizational and economic characteristics The object of the study is JSC "Krasnoyarsknefteproduct", the organization was assigned TIN 2460002949, OGRN 1022401784954. Organization JSC "Krasnoyarsknefteproduct" Krasnoyarsk, st. registered Dekabristov, "Krasnoyarsknefteprodukt" 30. at the address: Joint-stock registered 660021, the company by the administration of the Zheleznodorozhny district of the city of Krasnoyarsk on June 8, 1994 and re-registered by resolution of July 29, 1996 No. 1002 with the issuance of a certificate of state registration with a change in name, organizational and legal forms. The authorized capital of the company is 67,784,160 rubles. Shares were issued for the amount of the authorized capital in the amount of: 317,739 ordinary shares, with a par value of 160 rubles and 105,912 preferred shares of type A, with a par value of 160 rubles. The main activities of JSC Krasnoyarsknefteproduct are: - wholesale trade in fuel; - storage, warehousing of oil and its refined products; - retail trade in motor fuel; - retail trade in non-specialized stores primarily in food products, including drinks and tobacco products; - organization of cargo transportation; - production of steam and hot water (thermal energy) by boiler houses; - loading and unloading activities in inland water transport; - loading and unloading activities on railway transport; - implementation of investment activities. 33
At the moment, the main business partners of the plant are: - PJSC Gazpromneft; - JSC "Yenisei River Shipping Company"; - State Enterprise of the Krasnoyarsk Territory “KrasAvia”; - PJSC IDGC of Siberia; - Federal State Unitary Enterprise “Main Center for Special Communications”; - Federal State Unitary Enterprise "Mining and Chemical Combine"; - Spiders LLC; - PJSC "BINBANK"; - JSC Krasnoyarskkraigaz. JSC "Krasnoyarsknefteproduct" has various branches in the Krasnoyarsk region presented in table 6. Table 6 - Branches of JSC "Krasnoyarsknefteproduct" Name of branch "Central" "East" "North" Postal code 660037 663610 663141 "Zapadny" 662153 "Rybinsky" skiy" " South-East" "Igarsky" 663560 662300 662920 663200 Address Krasnoyarsk, lane. Tikhy, 1 G. Kans, st. Shosseynaya, 1 S. Abalakovo, Yenisei district, st. Novaya, 2 Krasnoyarsk region, Bolsheuluisky district, Industrial site of the G. Zaozerny oil refinery, Zheleznodorozhnikov lane, 1 G. Uzhur, st. Gogol, 15 P. Kuragino, st. Partizanskaya, 64 G. Igarskaya, st. Karl Marx, 1 The average headcount for the Company as a whole is 1,486 people in 2015, and 1,603 people in 2016. JSC "Krasnoyarsknefteproduct" Covers 40 districts of the Krasnoyarsk Territory, having 137 gas stations and 14 distribution oil depots, which allow creating a reserve of petroleum products in the amount of 275,934 tons. The organization has 2 water-railway facilities that provide transshipment of petroleum products to water. 34 terminals, which
Table 7 shows the distribution of revenue of Krasnoyarsknefteproduct JSC for 2016 by branches. Table 7 – Distribution of revenue for 2016 by division Name of branch Revenue, thousand rubles. Share in total revenue, % “Central” “Eastern” “Northern” “Western” “Rybinsky” “Uzhursky” “South-Eastern” “Igarsky” Unit Total 4225297 1416061 3390657 1194693 836040 1047094 1352439 73939 143073 13679293 30.9 10, 4 24.8 8.7 6.1 7.7 9.9 0.5 1 100 The Central branch is the largest division of the organization. Let us note that the largest share in the total revenue is occupied by the Central branch, namely 30.9%. The branch provides petroleum products to gas stations in Krasnoyarsk, Emelyanovsky, Sosnovoborsk, Zheleznogorsk, Bolshemurtinsky district and Divnogorsk, produces Mansky, and ships petroleum products to the Far North. The Igarsky branch occupies a smaller share in the total revenue, namely in absolute terms 73,939 thousand rubles. and in a relative form of 0.5%, which provides petroleum products to budgetary organizations of the city of Igarka. The branch includes one oil depot and one gas station. The supply of petroleum products to Igarka is possible only within the framework of northern delivery, which takes place during a short period of river navigation. Therefore, oil products are accumulated in the reservoirs of the Igarsk oil depot, which form an important part of the life support of the entire city for most of the year. 35
Table 8 - Organizational characteristics of JSC Krasnoyarsknefteproduct in 2016 Criteria Name Form of ownership Legal form Type of enterprise in accordance with the main activity Tax regime Necessity for mandatory audit Size of the enterprise Number of years of operation on the market Location Availability of other types of activities Assortment profile Main contingent of buyers (customers) Type of management structure Type of competitive environment Characteristics JSC "Krasnoyarsknefteprodukt" private joint-stock company trading enterprise general taxation system yes large enterprise 20 Krasnoyarsk, st. Depovskaya, 15, 660058. provision of laboratory services for analysis of the quality of petroleum products; provision of repair services; equipment for oil depots and gas stations; related products at gas stations; transport processing of goods. non-food products legal entities individuals linear-functional Oligopoly Table 9 - Analysis of the main financial and economic indicators of the activities of JSC Krasnoyarsknefteproduct for 2015-2016 Actually Indicators 1 Revenue from the sale of goods, products, works, services thousand rubles. 2 Cost of goods, products, works, services sold, thousand rubles. 3 Gross profit - amount thousand rubles. (page 1-page 2) - level, % (page 3/ page 1·100%) 4 Selling expenses, thousand rubles. 5 Administrative expenses, thousand rubles. 6 Profit (loss) from sales - amount thousand rubles. (page 3 - page 4 - page 5) - return on sales, % (page 6/ page 1/100) Absolute Rate of change deviation, (+ ; -) % 2015 2016 13446448 13679293 232845 101 .73 11613031 11714052 101021 100.87 1788210 1965241 177031 109.9 13.3 1423780 - 14.37 1506349 - 1.07 82569 - X 108.05 - 364430 458892 94462 125.92 2.71 3.35 0.64 X 36
End of table 9 Actually Indicators 7 Income from participation in other organizations, thousand rubles. 8 Interest receivable, thousand rubles. 9 Interest payable, thousand rubles. 10 Other income, thousand rubles. 11 Other expenses, thousand rubles. 12 Profit (loss) before tax Amount, thousand rubles. 13- profitability of activities (before taxation), % (line 12/line 1·100%) 14 Current income tax thousand rubles. 15 Net profit (loss) (page 12-page 14), thousand rubles. 16 profitability of final activities, % (page 15/page 1·100) 17 Average annual cost of property, thousand rubles. 18 Amount of authorized capital (average value), thousand rubles. 19 Retained earnings (loss) at the end of the year, thousand rubles. 20 Ratio of equity and borrowed funds 21 Net assets, thousand rubles. 22 Return on net assets, % 23 Operating profit before interest, taxes, taking into account depreciation, EBITDA, thousand rubles. 24 Share of EBITDA in revenue, % 25 Ratio of debt to EBITDA Absolute Rate of change, (+ ; -) % 2015 2016 8 36 28 450 63733 367835 184466 306721 10096 309937 213207 36089 8 -53637 -57898 28741 54177 15, 84 84.26 115.58 117.66 -61919 11396 73315 -18.4 -0.46 0.08 0.54 x 10359 36707 26348 354.35 -73087 82570 212.96-0.54 0.07 07 07 07 .61 X 4455603 4654758 199155 104.47 67784 67784 0 100 807195 7974868 -9327 98.84 3.3 3.8 0.5 115.15 1035623 -7 1026296 0.9 -93 27 7.9 99.1 X 357713 393292 35579 109.95 2.7 9.5 2.88 9.8 0.18 0.3 X X The analysis data presented in Table 9 showed that Krasnoyarsknefteprodukt JSC has observed an increase in revenue from the sale of goods, products, works, services in reporting year by 232,845 thousand rubles. and in relative terms by 1.73%. I would like to note that due to the increase in revenue, gross profit increased in relative terms by 9.9% or in absolute terms by 177,031 thousand rubles. 37
The cost of goods sold, products, works, services grew at a slower pace, namely by 0.87%, which indicates an improvement in the financial situation and deserves a positive assessment. It should be noted that other income in 2016 grew at a lower rate than other expenses, namely 15.58% growth in other income, against 17.66% growth in other expenses. The larger increase in other expenses was due to increased losses from previous years, costs of banking services and the emergence of acquiring expenses. Profit before tax in 2016 amounted to 11,396, which deserves a positive assessment, since the loss before tax was observed in 2015 and amounted to 73,083 thousand rubles, thereby the profitability of activities before tax showed an increase of 0.54% and amounted to 0.08%. . The current income tax is formed by the company taking into account the balance sheet provisions of PBU 18/02 “Accounting for income tax calculations”. Income tax amounted to 9487. The ratio of equity and borrowed funds in 2016 was 3.8 with the norm of this indicator being 0.5< Кс/з < 0,7. Коэффициент соотношения собственных и заемных средств характеризует финансовую устойчивость предприятия и показывает сколько заемных средств приходится на единицу собственного капитала. Данное значение показателя заслуживает негативной оценки, может привести к неустойчивому финансовому состоянию, к риску неплатежеспособности и банкротства из-за высокой концентрации заемного капитала. Отметим, что рентабельность чистых активов показала значительный рост и составила в 2016 году 0,9 пункта. Рентабельность чистых активов показывает эффективность управления структурой капитала, способность предприятия с отдачей распоряжаться собственным капиталом и кредитами банков. Рентабельность чистых активов считается самым важным показателем для акционеров, так как она показывает величину прибыли, которая приходится на собственный (акционерный) капитал. 38
After comparing the dynamics of EBITDA in the reporting period with the profitability of final activities (2.88 > 0.07), we can conclude that the cash flow generation processes are developing in a direction that meets the economic interests of the enterprise. Hence, we can say that the level of cash flow management is high, which reflects an increase in solvency in this period. The ratio of debt to EBITDA shows the solvency of the company in 2016; this ratio in JSC Krasnoyarsknefteprodukt was 9.8, this indicates that the company has too much debt and probable problems with repaying its debts. In general, the analysis allows us to give a positive assessment of the enterprise’s activities in the analyzed period, since there is an increase in revenue over time, net profit and an increase in its profitability. There was also a reduction in other expenses, which is a positive development for the company. Table 10 - Change in the structure of gross profit of Krasnoyarsknefteproduct JSC Indicators Gross profit, total Including: Gross profit from own sales Including: from wholesale sales from retail trade Gross profit from the provision of transshipment and storage services Gross profit from other activities 2016 year 2015 Amount, Specific weight, Amount, Specific weight, thousand rubles. % thousand roubles. % Change 2016 to 2015 Absolute, TP, thousand rubles. % 1965241 100 1788210 100 177031 110 1818001 93 1627368 91% 190633 112% 529044 29 424584 26% 104460 125 1147893 63 1057040 65% 90853 109 107901 5 144939 8% -37038 74 39339 2 15903 1 23436 247 39
Total gross profit in the amount of 1,965,241 thousand rubles, higher than the same indicator in 2015 by 10% or 177,031 thousand rubles. The increase was due to an increase in gross profit from wholesale and retail sales, as well as an increase in gross profit from other activities. Gross profit from own sales was received in the amount of 1,818,001 thousand rubles, which is higher than the same figure for 2015 by 2% or 190,633 thousand rubles. Including by type of sales, gross profit on wholesale sales amounted to 529,044 thousand rubles, which is 25% higher than in 2015 or 104,460 thousand rubles. For supplies to the Far North, gross profit amounted to 141,063 thousand rubles, which is 3% lower than in 2015 or 4,681 thousand rubles. The largest share in the structure of gross profit from own sales is occupied by gross profit from sales through a network of gas stations - 63% or in absolute terms 1,147,893 thousand rubles. Gross profit from the provision of transshipment and storage services amounted to 141,063 thousand rubles. compared to 2015, a decrease of 26% or 37,038 thousand rubles. Gross profit from other activities was received in 2016 in the amount of 39,339 thousand rubles, which is 147% higher than the same indicator in 2015 or 23,436 thousand rubles. Table 11 – Analysis of the structure of equity capital by purpose of JSC Krasnoyarsknefteproduct Indicators 1. Own capital, thousand rubles. 2. Long-term liabilities, thousand rubles. 3. Non-current assets, thousand rubles. Rate of change, % 2015 2016 Deviation, thousand rubles. 1035623 1026296 -9327 99.09 1149 1509 360 131.33 1018604 1158609 140005 113.74 40
End of table 11 Indicators 4. Own working capital, thousand rubles. (line 1+line 2-line 3) 5. Equity capital maneuverability ratio (line 4 / line 1) 2015 2016 Deviation, thousand rubles. Rate of change, % 18168 -130804 148972 719.97 0.01 -0.12 0.13 X The situation will be assessed positively in the case of a positive value of own working capital and their increase in dynamics, as well as if maneuverability corresponds to the optimal value (for trade enterprises 0.5%). Note that own working capital is a part of equity capital aimed at the formation of current assets. The analysis showed that the value of own working capital in 2016 is negative and at the same time in dynamics there is a decrease in comparison with 2015 by 148,972 thousand rubles. The indicator of equity capital maneuverability does not correspond to the optimal value and is -0.12. Table 12 – Analysis of the composition and structure of borrowed capital of Krasnoyarsknefteprodukt JSC 2015 Composition of borrowed capital 1. Total borrowed capital 2. Long-term liabilities 2.2. Estimated liabilities 2.3. Other long-term liabilities 3. Short-term liabilities 2016 Basic deviation (+;-) Spec. Amount, weight, thousand rubles. % TP in % Amount, thousand rubles. Ud. weight, % Amount, thousand rubles. Ud. weight, % 3385985 100 3861613 100 475628 X 114.05 1149 0.03 1509 0.04 360 0.01 131.33 - - - - - - - - - - - - - - 3384836 99.97 3860104 99.96 47 5268 -0.01 114.04 41
End of table 12 2015 Composition of borrowed capital 3.1. Borrowed funds 3.2. Accounts payable 3.3. Estimated liabilities 3.4. Other short-term liabilities 2016 Base deviation (+;-) Spec. Amount, weight, thousand rubles. % TP in % Amount, thousand rubles. Ud. weight, % Amount, thousand rubles. Ud. weight, % 2355437 69.56 2476124 64.12 120687 -5.44 105.12 984600 29.08 903745 23.40 -80855 -5.68 91.79 44799 1.32 47754 1.24 2955 -0, 09 106 .60 - X 432481 11.20 X X X When studying the structure of borrowed capital by maturity, the increase in the share of long-term liabilities is assessed positively, since they are one of the sources of financing the development and modernization of the material and technical base of business entities. Their growth helps to increase financial stability and current solvency. In 2016, JSC Krasnoyarsknefteproduct increased the share of long-term liabilities by 0.01% or 360 thousand rubles. When assessing the structure of short-term liabilities, the situation in which the largest share falls on accounts payable is positively assessed, since, provided that obligations to creditors are repaid on a timely basis, it is most often a “free” source of the formation of Krasnoyarsknefteprodukt in the current asset structure. short-term liabilities of JSC, the largest share falls on borrowed funds 64.12% or 2,476,124 thousand rubles. Borrowing capital in the reporting year increased by 14.05% or 475,628 thousand rubles. Short-term liabilities in 2016 showed an increase of 14.04% or 475,268 thousand rubles, which is assessed negatively. 42
Table 13 - Calculation of the influence of factors on the change in the net profit of JSC Krasnoyarsknefteproduct for 2015-2016 1 Growth (decrease) in sales revenue 2 Increase (decrease) in the average level of gross profit 3 Increase (decrease) in the average level of expenses for the sale of goods 4 Total influence on sales profit (line 1 + line 2) 5 Growth (decrease) in other income 6 Growth (decrease) in other expenses 7 Total impact on profit before tax (line 3 + line 4 + line 5) 8 Growth ( reduction) of current income tax 9 Increase (decrease) in deferred tax liabilities 10 Increase (decrease) in deferred tax assets 11 Total impact on net profit (line 6 + line 7 + line 8 + line 9) Impact analysis Calculation of the influence of factors Methodology Calculation of calculations Symbol Name of factors and direction of their change ВР ВР · Рпп0: Magnitude of influence, thousand rubles. 100 232845·(0.54):100 ∆ At VP ∆ At VP · BP1:100% 1.07·13679293:10 0 146368 ∆ At RP - (∆ At RP · BP1):100% (0.85·13679293 ):1 00 117140 ∆PP DPP(BP) + DPP(Uvp) -1257+146368 147625 DPrD PrD1 - PrD0 213207-184466 28741 DPr -(PrR1 PrR0) DPDN(PP) + DPDN(PrD) + DPDN(PrR) - (TNP1 TNP0) -(309937-367835) 57898 147625+28741+5 7898 234264 -(36707-10359) 26348 DPDN DTNP -1257 ∆ONO ∆ONO 1 ∆ONO 0 360-97 263 ∆ОНА ∆ОНА 1 ∆ОНА 0 32912 -(-669) 33581 DPP DPP(PDN) + DPP(ONA) + DPP(ONO) + DPP(TNP) 234264+26348+2 63+33581 294456 factors on the change in net profit of JSC "Krasnoyarsknefteprodukt" showed that the increase in the average level gross profit affected profit by - 146,368 thousand rubles. I would like to say that the decrease in the average level of costs for the sale of goods affected profit to a greater extent than revenue, namely by 117,140 thousand rubles. As a result, the impact on profit from the sale amounted to RUB 147,625 thousand. 43
Considering other income and expenses. A greater impact on the change in net profit was shown by an increase in other expenses of 57,898 thousand rubles. As a result, the impact on profit before tax amounted to RUB 234,264 thousand. Note that the increase in the amount of tax to the budget affected the change in net profit by 26,348 thousand rubles. The total impact on net profit amounted to 294,456 thousand rubles. Table 14 – Analysis of business activity of JSC Krasnoyarsknefteproduct Actual Indicators 1 Sales revenue, thousand rubles. 2 Net profit, thousand rubles. 3 Average annual value of assets, thousand rubles. 4 Average annual value of current assets, thousand rubles. 5 Speed of circulation of property (p.1/ p.3) 6 Time of circulation of current assets (p.4/ p.1*360) 7 Return on assets (p.2/ p.3*100) 8 Comprehensive indicator of business activity (p. .5+ p.7)/2 2015 2016 13446448 13679293 Absol. deviation 232845 -73083 9487 82570 212.96 4455603 4654758 199155 104.47 3558959 3566152 7193 100.20 3.78 3.84 0.06 101.59 95 94 - 1 98.95 -1.6 0.2 1, 8,212.50 X X X 157.04 Rate of change, % 101.73 Sales revenue increased slightly by 1.73%; in 2016 its value amounted to 13,679,293 thousand rubles. It is worth noting that the average annual value of assets increased by 4.47%; in monetary terms, the value of the indicator is 4,654,758 thousand rubles. This is due to the fact that the turnover rate of total capital, namely the assets of the enterprise, in 2016 showed an increase of 0.06% and amounted to 3.84, since this indicator shows how many times during the period under review the full cycle of production and circulation occurs, bringing the corresponding effect in the form of profit, it should be noted that net profit also increased by 82,570 thousand rubles. and its value amounted to 9487 thousand rubles. The circulation time of current assets decreased by 1 day, also 44
The average value of current assets increased and amounted to 3,566,152 thousand rubles. In general, business activity had a growth rate. The “golden rule” of enterprise economics was not fulfilled in 2016. It is worth noting that the growth rate of average assets is growing at a faster pace than revenue, which indicates a slowdown in asset turnover. Fulfillment of the first ratio (net profit grows at a faster pace than revenue) means an increase in the profitability of sales based on net profit. In JSC Krasnoyarsknefteproduct, the return on sales in terms of net profit in 2016 compared to 2015 increased by 0.61. The dynamics of business activity indicators showed that during the analyzed period there was a reduction in business activity from 6.92% to 5.62%. This dynamics was caused by a decrease in the turnover rate of property by 12%, as well as return on assets by 2.44%. The faster pace of increase in net profit compared to the average value of assets means an increase in return on assets. The return on assets in Krasnoyarsknefteproduct JSC in 2016 increased by 1.8 compared to 2015. A comprehensive indicator of business activity reflects the dynamics of the overall level of business activity. The optimal value is more than 100%. In JSC Krasnoyarsknefteproduct, the complex indicator of business activity amounted to 157.04%. To analyze the tax burden, it is necessary first of all to assess the financial condition of the organization; for this, we will assess the liquidity of the organization. An assessment of an organization's liquidity allows us to characterize the possibilities of timely settlement of short-term obligations and is carried out on the basis of the characteristics of the liquidity of current (current) assets. 45
Let's analyze the dynamics of liquidity of a commercial organization using table 15. Table 15 - Analysis of the dynamics of liquidity of a commercial organization Actually Indicators Absolute. deviation Rate of change, % 2015 2016 94126 114240 20114 121.37 1454486 1289527 -164959 88.66 1548612 1403767 -144845 90.65 1812603 227921 4 466611 125.74 3361215 3682981 321766 109.57 3343047 3813785 470738 114.08 7. Absolute liquidity ratio [line 1/ line 6] 0.02 0.03 0.01 150.00 8. Critical liquidity ratio [line 3/ line 6] 0.46 0.37 -0.09 80.43 9. Current liquidity ratio [line 5/line 6] 1.01 0.97 -0.04 96.04 1. Cash and short-term financial investments (line 1250+ 1240), thousand rubles. 2. Accounts receivable 3. Total cash and accounts receivable [line 1+ line 2], thousand rubles. 4. Inventories and other current assets (line 1210+ 1260), thousand rubles. 5. Total current assets [line 3+ line 4], thousand rubles, 6. Short-term liabilities (line 1500-1530-1220), thousand rubles. The analysis of the liquidity dynamics of Krasnoyarsknefteproduct JSC showed that the value of the absolute liquidity ratio does not correspond to the optimal value (0.1-0.2) and amounted to 0.03 in 2016, but this ratio showed an increase compared to 2015. It is worth noting that the absolute liquidity ratio characterizes the solvency of the organization, showing what part of short-term liabilities could be repaid as of that date using cash and short-term financial investments. The critical liquidity ratio showed a decrease in 2016, despite the decrease, it corresponds to the optimal value (0.2-1) and amounts to 0.37. 46
The current liquidity ratio did not reach the optimal value in 2016 (1-2) and amounted to 0.97. Next, we will calculate the tax burden of an enterprise - an important element of tax planning, which is an independent area of economic analysis. 2.2 Analysis of the formation of tax obligations, structure and dynamics of tax payments of JSC "Krasnoyarsknefteprodukt" JSC "Krasnoyarsknefteprodukt" taxation, therefore, is on the payer of the general system of the following types of tax obligations: - Organizational property tax; - Value added tax; - Corporate income tax; - Land tax; - Transport tax; - Water tax; - Insurance premiums (as of January 1, 2017, regulated by the Tax Code of the Russian Federation). The management of tax payments at the Krasnoyarsknefteproduct JSC enterprise is carried out by the Deputy General Director for Economics and Finance. Her responsibilities include: - development and justification of the application of an effective tax regime; - creation and maintenance of an information base on tax legislation; - development of corporate tax policy and tax budget; - implementation of corporate tax planning; - implementation of internal taxation of the organization; 47 tax control, analysis
Timely and complete provision of documentation to tax authorities; - implementation of tax proceedings (timely registration with the relevant authorities and re-registration, development of a tax calendar and regulation of payments for individual taxes). Below we present the tax field of the research object. Table 16 - Tax field of JSC "Krasnoyarsknefteproduct" for 2015-2016 Name of tax Organizational profit tax Organizational property tax VAT Personal income tax Insurance premiums Transport tax Land tax Water tax Tax base Chapter 25 of the Tax Code of the Republic of Kazakhstan. The monetary expression of an organization's profit. The average annual residual value of taxable objects, determined according to accounting data. Tax Code of the Russian Federation Chapter 21 Employee income reduced by the amount of tax deductions. Tax Code of the Russian Federation Chapter 34. Tax Code of the Russian Federation Chapter 28. Vehicle engine power in horsepower. The cadastral value of land plots recognized as an object of taxation in accordance with Art. 389 Tax Code of the Russian Federation. Tax Code of the Russian Federation Chapter 25.2. For each type of water use recognized as an object of taxation in accordance with Article 333.9 of the Tax Code of the Russian Federation. Rate 20% 2.2% 18%,0%,10% 13% 30% In rubles to the tax base and differentiated by type of transport. 1.5% In rubles per 1 thousand cubic meters. m. water. Please note that the tax field being compiled includes tax liabilities paid by the enterprise Krasnoyarsknefteproduct JSC in 2015-2016. Therefore, the tax field of an enterprise is not constant. Due to constant changes in tax legislation, significant changes may occur in the calculation and payment of taxes. 48
End of table 17 Indicator name Reserve for reduction in the value of inventory items Reserve for doubtful debts for other expenses that are not taken into account for taxation for losses of previous years Reserve for doubtful debts Permanent tax assets including: for income not taken into account for tax purposes (profits of previous years ) for expenses for the acquisition of the right to land plots revaluation of the value of other assets Increase in deferred tax assets, including due to: discrepancies in the timing and methods of calculating depreciation in accounting and tax accounting other transactions on fixed assets property and medical insurance reserve for holiday expenses for certification and licensing of products and services expert opinions on the costs of delivering and bringing the leased asset to a state in which it is suitable for use other Increase in deferred tax liabilities Including due to: Inconsistencies in the timing and methods of calculating depreciation in the accounting and tax accounting of other transactions by fixed assets By difference in methods for writing off workwear Income tax on corrective declarations Table 18 - Analysis of tax calculation for 2016 thousand rubles 205 - 2015 thousand rubles 1195 9399 2084 3096 5682 - 1016 34843 -10917 -30105 -9912 -253 -422 -583 -555 -29273 -24 32912 -669 197 251 22 -861 4711 95 -612 -171 -32 4 -27 -5 -22 29172 - 183 -360 -97 -186 -10 -174 -3597 -1 -86 - on the profit of JSC Krasnoyarsknefteproduct for 2015-2016 Name of indicator 1 Sales income 2 Non-operating income 3 Expenses that reduce the amount of sales income 4 Non-operating expenses 5 Losses in 2015, thousand rubles. 13447448 99295 2016 thousand rubles. 13685144 163906 Deviation, thousand rubles. 237715 64610 13099535 13211182 111647 39692 1347 454351 52 414658 -1295 50
End of table 18 Name of indicator 2015 thousand rubles 2016 thousand rubles Deviation (+;-) 51613 183569 131956 8 51794 36 183533 28 131738 10358 36706 26347 1035 9323 3670 33035 2634 23712 6 Total profit (loss) (page 1+ 2 +3 + 4 + 5) 7 Income excluded from profit 8 Tax base 9 total amount of calculated tax, including: to the federal budget to the budget of a constituent entity of the Russian Federation. According to the tables, it was determined that the company increased its income tax expenses by 26,347 thousand rubles during the analyzed period. due to an increase in the tax base, which in 2016 increased by 131,738 thousand rubles. Contributions to the regional budget amounted to 33,035 thousand rubles. in 2016, and 3670 thousand rubles. to the federal budget. It is worth noting that the increase in income tax was caused by an increase of 64,610 thousand rubles. income from sales, and expenses increased at almost the same rate, reducing the amount of income from sales and amounted to 13,211,182 thousand rubles. At the same time, non-operating income, the receipt of which is not directly related to the production and sale of products, increased significantly; their value amounted to 163,906 thousand rubles. in the reporting year. It is worth noting that in 2016 the company’s losses decreased compared to 2015, and their amount amounted to 52,185 rubles; this dynamics is assessed positively for the economic activities of the organization. The organization is also a transport tax payer. Within the framework of the legislation of 2015-2016, the accrual procedure took place on vehicles remaining on the balance sheet of the enterprise in the corresponding tax period. At JSC Krasnoyarsknefteproduct, the transport tax in 2016 amounted to 1,375 thousand rubles. It is worth noting that the transport tax showed a slight increase in 2016 compared to 2015. The increase in this tax in the reporting year amounted to 26 thousand rubles. This growth is caused to a large extent by an increase in 51
number of vehicles. The structure of vehicles included in the tax base for transport tax is presented in Figure 5. Figure 5 - Structure of vehicles included in the tax base for transport tax for 2015-2016, % The largest share is occupied by freight transport and other self-propelled vehicles, characteristic sectors of this organization. The property tax of organizations is calculated based on the average annual residual value of the property of organizations, refers to regional taxes, is established by the Tax Code of the Russian Federation and regional laws. The tax rate for corporate property tax is set at 2.2 percent. In accordance with the Tax Code of the Russian Federation, the tax period is a calendar year. Table 19 – Analysis of the dynamics and obligations of the property tax of JSC Krasnoyarsknefteproduct for 2015-2016 Name of the indicator Tax base, thousand rubles. Amount of calculated tax, thousand rubles. Amount of tax paid to the budget, thousand rubles. Actual 2015 2016 667933 833332 Deviation Rate of change, % 165399 124.76 14695 18333 3639 124.76 14695 18333 3639 124.76 52
The analysis of the dynamics and liabilities of the property tax of Krasnoyarsknefteproduct JSC showed that over two years it showed an increase of 165,399 thousand rubles. and amounted to 833,332 thousand rubles in 2016. This dynamics is associated with the creation of a new gas station, refurbishment of storage facilities and revaluation of the average annual value of property for the tax period. Taxpayers of water tax are organizations and individuals who, including individual water entrepreneurs, use water facilities that are subject to licensing in accordance with the legislation of the Russian Federation. Table 20 – Procedure for calculating the water tax of Krasnoyarsknefteproduct JSC Name of indicator Volume of water taken from a water body, thousand cubic meters. m. Tax rate, rub. Amount of tax to be paid, thousand rubles. 2015 2016 Deviation 131,448 120,141 -11,307 1415 186 1415 170 -16 – In 2016, the organization managed to reduce water tax expenses by 16 thousand rubles. This decrease is caused by a reduction in the volume of water taken from the water body in excess of the established limit by 11 thousand cubic meters. m. The water body is the Yenisei River. The tax rate for withdrawals in excess of the established limit is 1,415 rubles. In accordance with Article 388 of the Tax Code of the Russian Federation, taxpayers of land tax are organizations and individuals who own land plots on the right of ownership, the right of permanent perpetual use or the right of lifelong inheritable possession. The amount of tax for land plots owned by JSC Krasnoyarsknefteprodukt in 2015 amounted to 19,593 thousand rubles, in 2016 the amount of tax amounted to 20,026 thousand rubles. Value added tax is a form of withdrawal of part of added value to the budget, where added value is defined as 53
the difference between the cost of goods sold (work, services) and the cost of material costs attributed to expenses. Table 21 – Analysis of VAT payment by JSC Krasnoyarsknefteproduct for 2015-2016 Name of indicator 2015 2016 Deviation Rate of change, % Tax base, thousand rubles. The total amount of tax calculated taking into account the restoration tax amounts, thousand rubles. Total amount of tax subject to deduction, thousand rubles. Amount of tax payable to the budget, thousand rubles. 13446448 13679293 232845 101.73 2091266 2164661 73395 103.51 1908717 2037558 128841 106.75 182549 126902 -55647 69.52 Analysis of income accrual C in Krasnoyarsknefteproduct JSC showed that there was a decrease in the amount of tax in 2016 by 55647 compared to 2015 . As a result of the compensation, at the end of this period the company had to pay the amount of 182,549 thousand rubles to the budget. In 2015, as a result of the total amount of tax subject to deduction, in 2016 JSC Krasnoyarsknefteproduct reduced the amount of tax to 126,902 thousand rubles. VAT refers to federal taxes that are established by the Tax Code of the Russian Federation and are obligatory for payment throughout Russia. In addition, VAT refers to indirect taxes, since the final payer is the consumer of goods (works, services). As an indirect tax, VAT affects the pricing process and consumption patterns. When calculating and paying VAT, each taxpayer maintains tax records for this tax. True, it is usually not called that, but, nevertheless, maintaining a Purchase Book, a Sales Book, journals of received and issued invoices, as well as the execution of the Invoices themselves is, of course, tax accounting for value added tax. Book 54
purchases, sales book, invoice are maintained according to specially developed forms, which are approved by the Decree of the Government of the Russian Federation dated December 26, 2011. Let's consider the tax base for accrued insurance premiums. When calculating insurance premiums, the entire volume of payments that are included in the wage fund is the basis for calculating deductions of insurance premiums. Table 22 - Analysis of the dynamics of the composition and structure of insurance premiums of JSC "Krasnoyarsknefteprodukt" for 2015-2016 Indicators Payroll fund including: wages based on official salaries, tariff rates, compensatory payments, incentive payments, payment for unworked time 2015 amount , specific thousand rubles. weight, % 2016 specific amount, weight, thousand rubles. % Deviation by specific amount, thousand rubles. weight, % Rate of change, % 449347 100 486468 100 37121 - 108.26 262419 58.4 281665 57.9 19246 -0.5 107.33 128513 28.6 131833 27.1 3320 -1.5 102.59 33701 7.5 41349 8.5 7648 1 122.69 24714 5.5 31620 6.5 6906 1 12794 The growth of the wage fund showed an increase of 8.26%, amounting to 486,468 thousand rubles. There is an increase in all elements of the wage fund. Incentive payments showed the greatest increase, namely by 22.69% and amounted to 41,349 thousand rubles in 2016. It is worth noting that the main share is occupied by wages based on official salaries, tariff rates of 57.9% in 2016 and 58.4% in 2015. Next, we will formalize all the calculations carried out in Table 22, where we will trace the dynamics of each tax. 55
Table 23 - Analysis of the dynamics of accrued tax liabilities for JSC "Krasnoyarsknefteproduct" for 2015-2016 Indicator name Organizational profit tax Transport tax Organizational property tax Water tax Land tax Value added tax Insurance premiums Total Let's visually reflect 2015 thousand rubles. Ud. weight, % 2016 thousand rubles Ud. weight, % Deviation (+;-) Rate of change, % 10358 2.87 36706 10.57 26348 354.37 1349 0.37 1375 0.40 26 101.93 14695 4.07 18333 5.28 3638 124, 76 186 19593 0.05 5.42 170 20026 0.05 5.76 -16 433 91.40 102.21 182549 50.52 126902 36.53 -55647 69.52 132614 361344 36.70 1 00.00 143876 347388 41 .42 100.00 11262 -13956 108.49 96.14 structure of tax liabilities of Krasnoyarsknefteproduct JSC. Figure 6 – Structure of tax liabilities of Krasnoyarsknefteproduct JSC for 2015 - 2016, thousand rubles. 56
2015 50.52 36.7 Organizational profit tax Transport tax Organizational property tax Water tax Land tax 2.87 5.42 4.07 0.05 0.37 Value added tax Insurance premiums Figure 7 - Structure of tax liabilities of JSC "Krasnoyarsknefteprodukt" for 2015, % 2016 Organizational profit tax 10.57 0.4 5.28 Transport tax 0.05 41.42 5.76 Organizational property tax Water tax Land tax 36.53 Value added tax Insurance contributions Figure 8 - Structure of tax liabilities of JSC Krasnoyarsknefteproduct for 2016, % Analysis of the structure of tax liabilities of JSC Krasnoyarsknefteproduct shows that the main share is tax 57
for added value and insurance premiums. In 2016, the share of income tax increased, its share amounted to 10.57%. A smaller share is made up of deductions for water and transport taxes. I would like to note that JSC Krasnoyarsknefteprodukt is reducing tax liabilities by 3.86%. This decrease was caused by a decrease in value added tax by 30.48% or in absolute terms by 55,647 thousand rubles. In the next paragraph, we will calculate and analyze the tax burden of the enterprise. 2.3 Analysis of the tax burden and tax efficiency indicators of JSC Krasnoyarsknefteproduct Practice shows that an important role in the company is played by the justification and correct choice of a system of indicators for determining the tax burden and methods of their calculation. A generally accepted organization is the procedure for determining the calculation, tax burden developed by the Ministry of Finance of the Russian Federation. This method was not chosen by chance; it has a simple and average method of calculation by dividing all tax deductions by the taxpayer’s revenue. This method has the advantage that there are industry average indicators for it, which allow you to compare the tax burden of an organization with the average value for each industry. Tax burden values by type of economic activity are freely available. The Federal Tax Service publishes them at the end of each year. We will calculate the tax burden at JSC Krasnoyarsknefteproduct according to the methodology presented by the Ministry of Finance of the Russian Federation. 58
Table 24 - Calculation of the tax burden of JSC Krasnoyarsknefteproduct for 2015-2016 Period Calculation of the indicator Value of the indicator in JSC Krasnoyarsknefteproduct % 2015 NB2015 = 361344/13446448 100% 2.7 2.2 0.5 2016 NB2016 = 347388/13679293·100% 2.5 2.4 0.1 Industry average, % Deviation (+;-) Thus, in Krasnoyarsknefteprodukt JSC, the tax burden according to the Ministry of Finance methodology in 2016 was 2.5%, and according to for the country as a whole for this industry – 2.4%. JSC Krasnoyarsknefteproduct managed to reduce the tax burden in 2016 compared to 2015 by 0.2%. This dynamics deserves a positive assessment. Another, less important indicator that allows one to assess the risk of tax control, i.e. On-site tax audit and, as a consequence, the accrual of penalties, is the calculation of profitability indicators of sales and assets. The value of which should not differ by more than 10% in one direction or another. In Table 25 we compare return on sales and assets indicators with industry averages. Table 25 - Comparison of the organization's return on sales and assets with industry averages for 2015 - 2016 Period 2015 2016 Indicator name Return on sales Return on assets Return on sales Return on assets Indicator value in JSC Krasnoyarsknefteproduct, % Industry average, % Deviation (+; -) 2.71 7.1 -4.39 -1.6 6.5 -8.1 3.35 5.3 -1.95 0.2 6.4 -6.2 59
An analysis of the comparison of the return on sales and assets of Krasnoyarsknefteproduct JSC with the industry average for 2016 and 2015 revealed that the return on assets showed a significant deviation from the industry average, which may be a reason to take a closer look at the company and include it in the on-site inspection plan even with optimal indicators tax burden. Let us conclude: JSC Krasnoyarsknefteproduct is on the general taxation system. When carrying out its activities, the enterprise pays 6 types of taxes, and also pays contributions to compulsory insurance funds and fees for emissions into the environment. The largest weight in the structure of expenses is the payment of VAT and Insurance premiums; the amount of VAT decreased significantly during the analyzed period and amounted to 126,902 thousand rubles. In addition, it should be noted that corporate income tax plays a significant role in the tax structure. The total amount of taxes paid in 2016 amounted to 347,388 thousand rubles, which was 3.86% lower than the previous year. This decrease was caused by a decrease in VAT compared to 2015 and the existing overpayment of VAT at the beginning of the year in the amount of 55,647 thousand rubles. As part of this work, it was determined that there was a decrease in the tax burden by 0.2%. Next, the tax office will carry out an assessment of the enterprise’s efficiency. Initial policy management data for assessing the effectiveness of managing the tax burden are presented in Table 26. Table 26 – Initial data for assessing the effectiveness of managing the tax burden of an enterprise Name of indicator 1 Total amount of net profit or loss (NP) 2 Total amount of tax payments (NP) 3 Total volume sales of products (OR) 4 Amount of tax payments included in the price of products (NPts) 5 Gross income (GI) 60 Actually 2015 2016 thousand rubles. thousand roubles. -73083 9487 361344 347388 13446448 13679293 21571 21128 1788210 1965241
Table 27 – Calculation of coefficients characterizing the efficiency of taxation Calculation 2015 2016 Deviation (+;-) Eno = NP/NP -0.2 0.03 0.23 NP = NP/OR 0.027 0.025 -0.002 KNd = NPts/VD 0.011 0.01 -0.001 Name of indicator 1 Tax efficiency coefficient (ETC), units. 2 Tax intensity of product sales (HEr), units. 3 Income taxation coefficient (KTd), units. Based on the calculations presented in Table 27, we can conclude that the organization is experiencing an increase in net profit. If in 2015, for every 100 rubles of accrued taxes in an organization, there were 20 rubles of losses, then in 2016, for every 100 rubles of accrued taxes, there were already 3 rubles of profit. Note that the higher the coefficient, the better. After all, the indicator will increase if, as a result of optimization, the company pays less taxes than, say, last year or than planned at the beginning of the year. We conclude that this dynamics of indicators deserves a positive assessment. Considering the tax intensity of products, we note that this indicator allows us to determine the amount of tax payments per unit volume of products sold. In 2015, per 100 rubles of revenue there were 2.7 rubles of tax payments, and in 2016 there were 2.5 rubles. The analysis carried out in this chapter allows us to draw the following conclusion that the enterprise experiences a reduction in the tax burden with positive changes in the main financial and economic indicators of activity, but at the same time its size can be reduced to industry indicators, which indicates that the management of the enterprise is not fully is engaged in optimization of the tax burden. On the positive side, the organization saw revenue growth of 1.73%. 61
Profit before tax in 2016 amounted to 11,396, which deserves a positive assessment, since the loss before tax was observed in 2015 and amounted to 73,083 thousand rubles, thereby the profitability of activities before tax showed an increase of 0.54% and amounted to 0.08%. . It should be noted that the return on net assets showed a significant increase and amounted to 0.9 points in 2016. The negative aspects are that in the organization the ratio of equity and borrowed funds in 2016 was 3.8, while the norm for this indicator was 0.5< Кс/з < 0,7. Коэффициент отношение долга к EBITDA в 2016 году составил 9,8, что говорит о низкой платёжеспособности компании. Далее на основании проведенного анализа дадим рекомендации по совершенствованию политики управления налоговой нагрузкой предприятия. 62
3. Measures to improve the management of the tax burden of JSC "Krasnoyarsknefteprodukt" 3.1 Measures to improve the management of the tax burden of JSC "Krasnoyarsknefteprodukt" Based on the theoretical material studied and the analysis carried out in the framework of the second chapter, we came to the conclusion that, when developing recommendations for improving the management of the tax burden JSC Krasnoyarsknefteproduct needs to take into account the established dynamics of tax payments of the enterprise, as well as the specifics of its activities. The analysis showed that during the analyzed period the tax burden decreased. In fact, an enterprise has few options for reducing the tax burden. Thus, in terms of transport tax and property tax, the amounts of deductions are not significant and essentially are not an alternative to reducing the tax burden of an enterprise. Value added tax has a complex nature of its calculation. The tax is not calculated on the value added, but on the difference between the value added tax accrued on revenue and tax deductions. It is worth noting that the state has set limits on the amount of tax deductions by region, amounting to 84%. This means that if a taxpayer’s share of VAT deduction for 12 months is higher than this amount, then the tax authority carries out a tax audit on him as a matter of priority. We will calculate the share of tax deductions for VAT in JSC Krasnoyarsknefteproduct. Table 28 – Calculation of the share of tax deductions for VAT in JSC Krasnoyarsknefteproduct Name of indicator 1 Amount of tax calculated taking into account the restoration amounts of tax, thousand rubles. 63 2015 2016 2091266 2164661
loading of oil and petroleum products from railway tank cars, from automobile tanks, counting and dosing complexes for measuring the volume of liquid and dispensing a given dose when pumping petroleum products, electrical heating systems for top loading devices with a total cost of 13,600 thousand rubles. Let us note that Krasnoyarsknefteproduct JSC reconstructed and retrofitted tanks for storing petroleum products and their components at a total cost of 60,000 thousand rubles. The total amount of investment in fixed assets amounted to 85,623 thousand rubles. Clause 9 of Art. 258 of the Tax Code of the Russian Federation provides the taxpayer with the right to a depreciation bonus. This right, exercised by the taxpayer, is noted in the tax accounting policy. Let us note that the maximum value of the depreciation bonus today is 10% for fixed assets included in the first - second, as well as the eighth - tenth depreciation groups, and 30% for fixed assets included in the third - seventh depreciation groups. JSC Krasnoyarsknefteproduct uses the straight-line depreciation method. To calculate the depreciation rate using the linear method, we use the formula K = 1 100%, n (1) where K is the depreciation rate as a percentage of the original cost of the object; n is the useful life of this object. A = C · K, (2) where A is the amount of depreciation; C – primary cost of property; K – depreciation rate as a percentage of the original cost of the object. 65
A1 = C · AP (3) where A1 is the depreciation bonus; C – primary cost of property; AP is the rate of the applied depreciation premium. We will calculate depreciation in Table 29. Table 29 – Calculation of depreciation without taking into account the depreciation bonus for accounting objects Basic Conditions for calculating depreciation means Truck tractor Initial cost - 3507.7 thousand Kamaz 6460-73 rubles. Useful life – 72 months. Date of receipt: 08/01/2016 Depreciation group – IV (over 5 to 7 years inclusive) Fuel distribution Initial cost – 300 thousand rubles. SK700 Useful life – 72 months. Date of receipt: 06/01/2016 Depreciation group – IV (over 5 to 7 years inclusive). Devices for Initial cost – 13600 thousand rubles for draining and filling. oil and useful life – 72 months. petroleum products. Date of receipt: 02/01/2016 Depreciation group – IV (over 5 to 7 years inclusive). Tanks for Initial cost – 60,000 thousand rubles storage. petroleum products. Useful life – 72 months. Date of receipt: 02/01/2016 Depreciation group – IV (over 5 to 7 years inclusive). Calculation K = (1/72) 100% = 1.39 A = 3507.6 (1.39/100) 4 3 = 585.12 thousand rubles. K = (1/72) 100% = 1.39 A = 300 (1.39/100) 6 5 = 125.1 thousand rubles. K = (1/72) 100% = 1.39 A = 13600 (1.39/100) 10 = 1890.04 thousand rubles. K = (1/72) 100% = 1.39 A = 60000 (1.39/100) 10 = 8340 thousand rubles. Depreciation charges excluding the depreciation bonus in 2016 amounted to 10,940.26 thousand rubles. We will calculate depreciation using the depreciation premium in table 30. 66
Table 30 - Calculation of depreciation taking into account the depreciation bonus for accounting objects Basic Conditions for calculating depreciation means Truck tractor Initial cost - 3507.7 thousand Kamaz 6460-73 rub. 3 pcs. = 10523 thousand rubles. Useful life – 72 months. Date of receipt: 08/01/2016 Depreciation group – IV (over 5 to 7 years inclusive). Depreciation bonus 30%. Calculation K = (1/72) 100% = 1.39 A1 = 10523 (30/100) = 3156 thousand rubles. A = (10523-3156)·(1.39/100) = 102.4 thousand rubles. A = 102.4·4 = 409.6 thousand rubles. Fuel dispensers SK700 Initial cost – 300 thousand rubles. ·5 pieces. =1500 thousand rubles. Useful life – 72 months. Date of receipt: 06/01/2016 Depreciation group – IV (over 5 to 7 years inclusive). Depreciation bonus 30%. K = (1/72) 100% = 1.39 A1 =1500 (30/100) = 450 thousand rubles. A = (1500-450)·(1.39/100) = 14.595 thousand rubles. A = 14.595 4 = 58.38 thousand rubles. Devices for draining and loading oil and petroleum products. Initial cost – 13,600 thousand rubles. Useful life – 72 months. Date of receipt: 02/01/2016 Depreciation group – IV (over 5 to 7 years inclusive). Depreciation bonus 30%. K = (1/72) 100% = 1.39 A1 = 13600 (30/100) = 4080 thousand rubles. A = (13600-4080)·(1.39/100) = 132.32. A = 132.328·10= 1323.28 thousand rubles. Tanks for storing petroleum products. Initial cost – 60,000 thousand rubles. Useful life – 72 months. Date of receipt: 02/01/2016 Depreciation group – IV (over 5 to 7 years inclusive). Depreciation bonus 30%. K = (1/72) 100% = 1.39 A1 = 60,000 30/100 = 18,000 thousand rubles. A = (60000-18000)·(1.39/100) = 583.8. A = 583.8·10 = 5838 thousand rubles. Depreciation charges, taking into account the depreciation bonus, in 2016 amounted to 33,315.26 thousand rubles. Please note that in subsequent periods, depreciation will be calculated as usual. The calculation results are presented in Table 31. 67
Table 31 – Amounts of depreciation charges of Krasnoyarsknefteprodukt JSC Depreciation charges without using a depreciation bonus using a depreciation bonus thousand rubles. thousand roubles. 10940.26 33315.26 14936.548 10461.548 14936.548 10461.548 14936.548 10461.548 14936.548 10461.548 14936.548 10461.548 Period 1 year 2 year 3 year 4 year 5 year 6 year Total for the entire useful life. Depending on the depreciation bonus 85623, the company can distribute the payment of income tax amounts over time. Let's estimate the amount of tax savings; for this we use the following formula SNE = A·STp (4) where SNE is the amount of tax savings; A – the amount of depreciation charges; STP – corporate income tax rate. Table 32 – Amount of potential tax income Period 1 year 2 year 3 year 4 year 5 year 6 year Total for the entire useful life Amount of tax savings, thousand rubles. without application using depreciation bonus depreciation bonus 2188.052 6663.052 2987.3 2092.3 2987.3 2092.3 2987.3 2092.3 2987.3 2092.3 2987.3 2092.3 17124.6 68 17124, 6
It is worth noting that the total tax savings are the same. However, the distribution of tax savings over time can have a significant impact on the company. An organization experiencing a shortage of available cash, and there is a need to update fixed assets, using bonus depreciation, can significantly reduce the tax base for corporate income tax in the first year. For example, by applying the depreciation bonus in 2016, Krasnoyarsknefteprodukt JSC will reduce income tax by 6,663.052 thousand rubles. Considering the obtained result shown in Table 31 as an investment project for a period of 6 years, we will calculate the net present value of investments using the method of S.G. Laleva, leading specialist of JSC "Prognoz". To calculate the net present value of investments, we use the following formula NPV = n t 1 NCFt (5) (1 r) t where NPV is the net present value of investments; NCF – net cash flow for period t; r – discount rate; t – project implementation period. The discount rate chosen is 20%. Let us calculate the value of the net present value of investments without bonus depreciation NPV = 2188.052 2987.3 2987.3 2987.3 2987.3 2987.3 = 9267.7 2 4 4 5 (1 0.2) ( 1 02) (1 02) (1 02) (1 02) (1 02) 6 69
Table 34 – Dynamics of accrued taxes for 2016, taking into account optimization schemes 36706 1375 18333 170 20026 Taking into account changes, thousand rubles. 30017 1375 18333 170 20026 126902 126902 0 100.00 143876 347388 143876 340669 0 -6689 100.00 98.07 2016, thousand rubles. Indicator Income tax Transport tax Property tax Water tax Land tax Value added tax Insurance premiums Total Deviation, thousand rubles. Rate of change, % -6689 0 0 0 0 81.78 100.00 100.00 100.00 100.00 Analysis of the dynamics of accrued taxes for 2016, taking into account optimization schemes, showed that with a reduction in income tax by 6689 thousand rubles. or in relative form by 18.22%, the total amount of taxes will be reduced by 1.93%. The total economic effect will be reflected in Table 35. Table 35 – Calculation of the economic effect of the proposed measures Indicators Reporting year Revenue, thousand rubles. Total amount of taxes, thousand rubles. Tax burden according to the methodology of the Ministry of Finance of Russia, % 13679293 After the measures 13679293 347388 340669 -6689 2.5 2.4 -0.1 Change - According to the results of calculations, the total amount of taxes decreased by 6842 thousand rubles, the total effectiveness of all proposed measures reflects reduction in the level of tax burden of Krasnoyarsknefteprodukt JSC, calculated according to the methodology of the Ministry of Finance of Russia by 0.1%, its level was 2.4%. The industry average tax burden is about 2.4%. 73 for this type of activity
According to the calculation results, the most effective method of reducing the tax burden is the use of bonus depreciation. This method made it possible to reduce income tax by 6,842 thousand rubles. Next, we will consider how the developed measures affected the net cash flow and financial result of Krasnoyarsknefteproduct JSC. Table 36 – Cash flow statement taking into account changes Cash flows from current operations Receipts - total 18003839 Taking into account the proposed measures, thousand rubles. 18003839 including: from the sale of products, goods, works and services rental payments, license payments, royalties, commissions and other similar payments from the resale of financial investments other receipts Payments - total including: to suppliers (contractors) for raw materials, supplies, work , services in connection with the payment of employees interest on debt obligations of corporate income tax other payments Balance of cash flows from current operations Cash flows from financial transactions Receipts - total 17487763 17487763 6387 6387 0 509689 18296063 16930596 0 509689 18296063 169305 96 728792 311250 36706 325401 -292225 7907552 728792 311250 30017 325401 -285536 7907552 including: receipt of loans and borrowings of cash deposits of owners (participants) from the issue of shares, increase in participation interests from the issue of bonds, bills and other debt securities and other other receipts Payments - total including : owners (participants) in connection with the repurchase of shares (participatory interests) of the organization from them or their release to pay dividends and other payments for the distribution of profits in favor of the owners (participants) 7907552 7907552 0 0 0 0 0 0 0 7805530 0 0 7805530 0 19798 19798 2016, thousand rubles. Indicator name 74
End of table 36 2016, thousand rubles. Name of the indicator in connection with the repayment (redemption) of bills and other debt securities, repayment of loans and other payments Balance of cash flows from financial transactions Balance of cash flows for the reporting period Balance of cash and cash equivalents at the beginning of the reporting period Balance of cash and cash equivalents at the end of the reporting period The magnitude of the impact of changes in the foreign currency exchange rate against the ruble 7785552 Taking into account the proposed measures, thousand rubles. 7785552 0 102022 38277 66162 0 388966 66162 104439 10975 0 0 As a result of the proposed measures to manage the tax burden of Krasnoyarsknefteproduct JSC, the company’s net cash flow increased by 6689 thousand rubles, thus we obtain efficiency from the measures taken, since in the end cash flows increased, and cash is the most liquid category of assets that provide the organization with the greatest degree of liquidity. One of the main areas of financial management of organizations is cash flow management. Managing the cash flows of organizations is inextricably linked with the self-financing strategy, since it involves identifying the relationship between cash flows and the organization’s profit. The released cash flow, due to a reduction in tax liabilities for income tax, can be used by JSC Krasnoyarsknefteprodukt to pay off accounts payable, which will help improve the efficiency of managing debt obligations, which are problematic for JSC Krasnoyarsknefteprodukt. It is worth adding that taking into account the proposed measures, the absolute liquidity ratio will increase by 0.01 and amount to 0.04, which indicates an increase in solvency in the company. 75
The economic efficiency of the proposed measures to reduce the tax burden is characterized by a decrease in the tax liabilities of Krasnoyarsknefteprodukt JSC by 6,689 thousand rubles, a decrease in the level of the tax burden by 0.1%. 76
The tax burden of Krasnoyarsknefteprodukt JSC as a result of measures taken to reduce the tax burden decreased by 0.1%, savings on tax payments amounted to 6,689 thousand rubles. According to the calculation results, the most effective method of reducing the tax burden is the use of bonus depreciation. By applying the depreciation bonus, Krasnoyarsknefteprodukt JSC will reduce income tax in 2016 by 18.22% and increase the net present value of the project by 24%. The increase in cash flow was largely influenced by the use of bonus depreciation. With the help of which the organization managed to increase depreciation deductions in 2016, which led to a reduction in the tax base for calculating income tax. At the same time, depreciation does not lead to a direct expenditure of cash, and thereby increases cash inflow for the enterprise. The measures that were proposed in the thesis bring the desired economic effect, namely a reduction in the tax burden and an increase in net cash flow. 78
LIST OF SOURCES USED 1. Tax Code of the Russian Federation. In 2 parts. Part 2 [Electronic resource]: Federal Law of December 28, 2016 No. 475-FZ // Reference legal system “ConsultantPlus”. – Access mode: http://www.consultant.ru/. 2. Tax Code of the Russian Federation. In 2 hours. Part 2 Electronic resource]: federal law dated 05.08.2000 No. 117-FZ as amended on 04.05.2017 // Reference legal system “ConsultantPlus”. – Access mode: http://www.consultant.ru/. 3. On the commission for the legalization of the tax base [Electronic resource]: Letter of the Federal Tax Service of the Russian Federation dated March 21, 2017 No. ED-4-15/5183 // Reference legal system “ConsultantPlus”. – Access mode: http://www.consultant.ru/. 4. On the calculation of insurance premiums [Electronic resource]: Letter of the Federal Tax Service of the Russian Federation dated 03/07/2017 No. BS-4-11/4091 // Reference legal system “ConsultantPlus”. – Access mode: http://www.consultant.ru/. 5. On identifying the circumstances of an unjustified tax benefit [Electronic resource]: Letter of the Federal Tax Service of the Russian Federation dated March 23, 2017 No. 547 // Reference legal system “ConsultantPlus”. – Access mode: http://www.consultant.ru/. 6. Astrakhantseva, I.A. Guidelines for practical training in the discipline financial policy of an organization: for bachelors in the field of study 380301.04.07 “Finance and Credit” (organizational finance) / Sib. Feder. University, Torg-econ. int.; developer Ph.D., Associate Professor I.A. Astrakhantseva. – Krasnoyarsk, 2016. – 127 p. 7. Bakanov, M.I. Theory of economic analysis: textbook / M.I. Bakanov, A.D. Sheremet. – Moscow: Finance and Statistics, 2012, – 536 p. 8. Lalev, S.G. Depreciation bonus as a tool for optimizing taxation / S.G. Lalev // Scientific life. - No. 9 – P. 65. 9. Bank of Russia [Electronic http://www.cbr.ru/. 79 resource]. - Access mode:
10. Burganov, R.A. Managerial economics: textbook / R.A. Burganov. - Moscow: INFRA-M, 2017. - 190 p. 11. Accounting Assistant 2011 - 2017 [Electronic resource]. - Access mode: http://buhpomoshnik.ru/. 12. Vilkova, E.S. Tax planning: textbook / E.S. Vylkova. – Moscow: Yurayt, 2012. – 97 p. 13. Vondertays magazine: taxes and accounting [Electronic resource]. - Access mode: http://wonderties.com/. 14. Gerasimenko, V.P. Finance and credit: textbook / V.P. Gerasimenko, E.N. Rudskaya. – Moscow: INFRA-M: Academcenter. 2013. – 384 p. 15. Journal of the Chief Accountant [Electronic resource] - Access mode: http://www.glavbukh.ru/. 16. Zanadvorov, V.S. Economic theory of public finance: textbook / V.S. Zanadvorov, M.G. Kolosnitsyn. - Moscow: State University Higher School of Economics, 2012. - 210 p. 17. Ivasenko, A.G. Finance of organizations (enterprises): textbook / A.G. Ivasenko, Ya.I. Nikonova. – Moscow: KNORUS, 2010. – 208 p. 18. Information about the company / Krasnoyarsknefteproduct [Electronic resource]. – Access mode: http://www.knp24.ru/. 19. Qualified assistance to your business [Electronic resource]. - Access mode: http://kreakom.ru/articles/. 20. Kozenova, T.S. Tax planning at an enterprise: textbook / T.S. Kozenova. - Moscow: Omega-L, 2012. – 315 p. 21. Kruglyak, Z.I. System of analytical indicators of taxation of economic entities / Z.I. Kruglyak // Scientific journal of KubSAU. – 2017, No. 3. – pp. 21-25. 22. Lykova, L.N. Taxes and taxation: textbook / L.N. Lykova. - Moscow: Yurayt, 2015. - 353 p. 23. Makarkina, N. L. Tax burden / N. L. Makarkina. – Moscow: Yurayt, 2013. - 207 p. 80
24. Blueberry, D.G. Taxes and taxation: textbook and workshop for secondary vocational education / D. G. Chernik. - Moscow: Yurayt, 2016. - 495 p. 25. Tchaikovsky L.A. Taxes and taxation: a textbook for secondary vocational education / L. A. Tchaikovskaya. - Moscow: Yurayt, 2016. - 503 p. 26. Malis. N.I. Tax policy of the state: textbook / edited by N. I. Malis. - Moscow: Yurayt, 2015. - 388 p. 27. Tax planning [Electronic resource] - Access mode: http://www.pnalog.ru/. 28. Scientific Forum [Electronic resource] - Access mode: http://www.nauchforum.ru/. 29. Redin, D.V. Possibilities for assessing and managing risks of the level and structure of an enterprise’s tax burden: textbook / D.V. Redin. - Moscow: Yurayt, 2016. - 120 p. 30. Ordynskaya, E.V. Organization and methodology of tax audits: textbook / E.V. Ordynskaya. – Moscow: Yurait, 2015. - 406 p. 31. Ostrovenko, T.K. Tax burden on an enterprise, general and particular indicators of the system / T.K. Ostrovenko // Audit statements. - 2012. - No. 1. – pp. 23-28. 32. Plaskova, N.S. Financial analysis of an organization’s activities: textbook / N.S. Plaskova. - Moscow: University textbook: INFRA-M, 2017. - 368 p. 33. Plaskova, N.S. Analysis of financial statements prepared according to IFRS: textbook / N.S. Plaskova. - 2nd ed., revised. and additional - Moscow: University textbook; INFRA-M, 2017. - 269 p. 34. Panskov, V.G. Taxes and taxation: textbook / V.G. Panskov. Moscow: Yurait, 2016.- 336 p. 35. Redin D.V. Possibilities for assessing and managing risks of the level and structure of an enterprise’s tax burden / D.V. Redin // Journal of Science. – 2017, No. 3. – pp. 21-25. 81
36. Savitskaya, G.V. Analysis of the economic activity of an enterprise: textbook / G.V. Savitskaya – 6th ed., revised. and additional – Moscow: Infa – M, 2013. – 607 p. 37. Savitskaya, G.V. Economic analysis: textbook / G.V. Savitskaya. - 14th ed., revised. and additional - Moscow: INFRA-M, 2013. – 649 p. 38. Fridman A.M. Finance of organizations: textbook / A.M. Friedman. - Moscow: INFRA-M, 2017. - 202 p. 39 Sheremet, A.D. Analysis and diagnostics of financial and economic activities of an enterprise: textbook / A.D. Sheremet. - 2nd ed., add. - Moscow: INFRA-M, 2017. - 374 p. 40 Sheremet, A.D. Theory of economic analysis: textbook. – 3rd ed., add. / A.D. Sheremet. – Moscow: INFRA-M, 2011. – 352 p. 82
LIST OF APPENDICES Appendix A Balance sheet as of December 31, 2016 Appendix B Statement of financial results as of December 31, 2016 Appendix B Statement of changes in capital as of December 31, 2016 Appendix D Explanatory note to the financial statements for 2016 Appendix E Cash flow statement for 2016 as of December 31, 2016 Appendix E Tax return for income tax for 2015–2016 Appendix E Tax return for value added tax for 2015–2016 Appendix G Tax return for transport tax for 2015–2016 Appendix H Tax return for water tax for 2015 - 2016 Appendix I Tax return for corporate property tax 2015 - 2016 Appendix J Tax return for land tax for 2015 - 2016 83
In the financial management system, managing the tax burden is of particular importance not only because taxes are one of the most significant types of expenses, but also because errors in tax planning can bring significant losses to the organization in the form of sanctions for violation of tax laws. Analysis of the tax burden allows you to assess the effectiveness of managing the most important type of expenses of an organization - its tax payments, assess tax risks associated with tax planning, and also develop basic directions of tax policy. The development of a tax payment management policy includes an analysis of the structure and dynamics of tax payments, indicators of the tax burden, as well as an analysis of income tax calculations.
In terms of main taxes, tax payments have the following structure:
Income tax;
Value added tax;
Unified social tax (contributions for social needs);
Property tax;
Other taxes.
204 II. Short-term financial policy
Analyzing the indicators of tax payments, it is advisable to evaluate the structure of revenue according to its tax-intensive and non-tax-intensive components. Tax-intensive components of revenue are those whose growth leads to an increase in tax payments, and non-tax-intensive components are those whose increase leads to their decrease. Many methods of tax planning lead to a reduction in tax-intensive components and an increase in non-tax-intensive ones. The relationship between the revenue structure and the main taxes is presented in Table. 5.21.
Table 5.21. Relationship between revenue structure and main taxes
Thus, a non-tax-intensive structure of revenue will be one in which material costs, other costs, and depreciation of intangible assets predominate, while profits, labor costs, contributions for social needs, and depreciation of fixed assets are insignificant. To assess the structure of revenue, it is advisable to use indicators of the “average” structure, which, according to Rosstat, are as follows (methodology of the Ministry of Finance): the share of profit before tax - 15%, labor costs - 12.75, contributions for social needs - 3.57, total the share of material costs, depreciation, and other costs is 68.68% 1.
An assessment of the effectiveness of tax payment management is provided by a comparative analysis of the dynamics (growth rates) of the main economic
1 Double entry. No. 2. 2007. pp. 42-48.
5. Operations management 205
Michal indicators of the organization, i.e. tax bases and its tax payments. An effective tax policy will correspond to an increase in tax bases with a slightly slower increase in tax payments.
The following indicators are used for comparative analysis.
Growth rate of economic indicators:
Revenue (net);
Accrued value added (revenue minus ma
material costs);
Paid added value (receipts from the purchase
tels minus payments to suppliers);
Net value added (revenue minus materials
nal costs, other costs and depreciation);
Profit from sales;
Profit before tax;
Net profit;
Balance currencies;
Own fixed assets;
Number of employees;
Labor costs.
Growth rate of tax payments:
Total payments of the organization;
Payments for taxes and fees (without social funds);
Contributions to social needs and social funds;
Current income tax.
Another aspect of analyzing the relationship between an enterprise and the state is the assessment of total tax assets and liabilities, their share in the assets and liabilities of the balance sheet. Under tax assets in this case, the sum of deferred tax assets, the item “VAT on acquired assets” and budget receivables to the organization is understood; under tax obligations- the amount of deferred tax liabilities and accounts payable for taxes and social funds. A positive tax position (the difference between tax assets and liabilities) is unfavorable for the organization, since it represents a free loan to the state; a negative one is beneficial. Therefore, significant tax assets can be considered a sign of ineffective management of tax payments. In addition, the item “VAT on acquired assets” is characterized by low liquidity and therefore worsens the quality of the organization’s current assets. Indicator “VAT on purchases”
206 II. Short-term financial policy
New values”, taking into account that the procedure for deducting VAT has changed, includes:
VAT amounts on purchased valuables, not registered
properly with supplier invoices, under-
contractors, other creditors;
Unpaid amounts of VAT on purchased assets in
regarding the customs value of goods imported into the territory
rhetoric of the Russian Federation;
Amounts of VAT on items purchased but not accepted for accounting
lic accounting of fixed assets and intangible assets.
VAT amounts for goods (works, services) used
for the production and (or) sale of goods (works, services),
taxed at a rate of 0%, but for which the tax authority
a decision on compensation (credit, refund) has not yet been made;
Relative indicators are used to assess the tax burden. For these purposes, under tax burden implies a relationship between tax payments and financial results. To assess the total tax burden, the ratio of the amount of payments an organization makes to the budget and social funds to financial results is used: total income, including revenue and other income; revenue (net); income from current activities; added value; net value added and estimated profit. Also, the tax burden can be calculated per unit of physical indicator, for example, per employee, per 1 sq. m area. For the purposes of this calculation, added value is defined as the difference between revenue and material costs. In addition, added value can be calculated as the difference between receipts from current activities and payments to suppliers for purchased goods, works, services, raw materials, etc.; this is a measure of “paid” added value. Net added value is the difference between revenue and material costs, depreciation, and other costs. Estimated profit is the sum of the organization’s net profit and payments to the budget and social funds; this is the organization’s profit in the absence of payments to the state. The tax burden on estimated profit shows the percentage of withdrawal by the state of the profit earned by the organization in conditions of its functioning in a tax-free environment.
The tax burden on wages shows how much the organization and employee must pay to the budget and social funds per each ruble of wages paid. Show-
5. Operations management 207
The values for assessing the tax burden are calculated using the following formulas:
organizations:
where ∑ N - total tax payments to the budget and social funds;
IN - revenue (net) from the sale of products;
where P POK - receipts from customers.
Where MOH- material costs (net).
Tax burden on paid added value:
Where P post- payments to suppliers.
Tax burden on net added value:
Where A - depreciation;
Zpr - other costs.
Where P h - net profit.
208 P- Short-term financial policy
where Ф с - payments to social funds;
ZOT- labor costs;
– tax rate on personal income.
Where H- average number of employees.
Tax burden indicators calculated in relation to ъ It is advisable to compare the financial and non-financial indicators of the enterprise, in particular the tax burden on revenue, profit, wages, one-hour employee, unit of area of production premises, unit of power, with industry indicators, taking into account the regional characteristics of the taxation of the organization.
For a comparative analysis of the tax burden on an organization, you can use the published methodology for calculating the “ideal” tax burden 1. Taking into account the “ideal” indicators of the revenue structure, the tax burden for the three main taxes - VAT, income tax and payments to social funds - is calculated as follows. Let the revenue be 100 million rubles. then payments for income tax, VAT and social funds will be calculated as follows:
P n= 0.24 ∙ 15 + 0.18 ∙ (100 – 68.68) + 3.57 = 12.808 million rubles.
Taking into account the obtained values, the tax burden relative to revenue (net) will be equal to 12.81%, relative to net added value - 40.89, relative to estimated profit - 52.91%.
“Ideal” tax burden on labor costs, calculated for a conditional level of labor costs in the amount of 10 million rubles. (without using a regressive scale), determined by the formula, i the numerator of which is the sum of the single social tax and income tax, and the denominator is the paid wages, cleared of income tax:
1 Double entry. 2007. No. 2. P. 42-48.
5. Operations management 209
Based on the results of calculating the relative indicators of the tax burden, the directions of tax policy are determined. The reasons for a significant decrease in the relative tax payments of an organization compared to the “ideal” or industry average burden should be carefully studied to assess the safety of the tax optimization methods used. It is believed that the tax burden on revenue, not exceeding 9%, serves as a sign of the tax optimization methods used by the organization. A tax burden that significantly exceeds the reference values is a sign of ineffective management of an organization's tax payments.
Reflection in reporting in accordance with PBU 18/02 of such indicators as deferred tax assets and deferred tax liabilities, permanent tax assets and permanent tax liabilities expands the possibilities for managing income tax payments. In particular, it allows us to understand why, if there is an insignificant accounting profit, an organization is forced to make significant payments for income tax, and vice versa (which happens much less often). In addition, reflecting such indicators as deferred tax assets and liabilities in the balance sheet allows us to assess future tax payments: deferred tax assets in the future will lead to a decrease in tax payments for income taxes, and deferred tax liabilities will lead to their increase.
Analysis income tax calculations allows you to evaluate the effectiveness of tax planning, as well as the completeness and efficiency of using legal tax optimization opportunities in the organization’s activities.
Net profit taking into account the requirements of PBU 18/02 is calculated as follows:
P h = P D + ONA 1 – ONA 2 – ONO 1 + ONO 2 -N p -P p, where P d - profit before tax;
SHE 1- deferred tax assets arising in the current reporting period;
SHE 2 - deferred tax assets settled in the current reporting period;
IT 1 - deferred tax liabilities arising in the current reporting period;
IT 2 - deferred tax liabilities settled in the current reporting period;
N p- Current income tax;
P P - payments from net profit (for example, penalties to the budget).
210 II. Short-term financial policy
The relationship between the current and conditional income tax is represented by the formula
N p = t∙ P d + PNO- PNA + SHE 1 - SHE 2 – IT 1 + IT 2,
Where t- profit tax rate;
PNO - ongoing tax obligations;
PNA - permanent tax assets.
Deferred tax assets reporting year, reflected in the income statement, must correspond to the deferred tax assets reflected in the balance sheet:
SHE = SHE K - SHE N,
Where SHE- the amount of deferred tax assets arising and
repaid in the reporting year;
SHE K, SHE N - deferred tax assets accordingly
at the end and beginning of the year.
Similar relationships must hold for deferred tax liabilities:
IT = IT K - IT N,
Where IT- the amount of deferred tax liabilities arising and
repaid in the reporting year;
IT K, IT N- deferred tax liabilities accordingly
at the end and beginning of the year.
Comparison conditional And current tax allows you to assess how beneficial the relationship between these two quantities is for the organization. It is beneficial for the organization if the conditional tax exceeds the current one, since the excess is a consequence of the fact that the organization pays a relatively lower tax on the received accounting profit. The reason for such a favorable circumstance for the organization may be the presence of permanent tax assets and deferred tax liabilities.
Current income tax can be calculated using the formula
N p = t∙P d + PNO – PNA + SHE – IT.
If you divide the left and right sides of the expression by the income tax rate, you get a formula for calculating taxable profit:
P n = P d +P p+ -P p- +P in – P in,
Where R p+ - constant difference is positive);
R p - - constant difference (negative);
Р вв - temporary deductible difference;
R vn - temporary taxable difference.
5. Operations management 211
Permanent positive differences that result in permanent tax liabilities increase the current income tax of the reporting period relative to the conditional tax and, in particular, are formed due to the following factors:
Adjustments (increases) of tax revenues according to
vii from Art. 40 Tax Code of the Russian Federation. In this case, accounting income
turn out to be lower than tax ones, since the prices of transactions for the purpose of
taxes increase in accordance with market rates;
Excesses of actual expenses taken into account when
formation of accounting profits, expenses, acceptance
for tax purposes, for which there are provisions
restrictions on expenses (costs of voluntary insurance
employees, research and development costs
travel, compensation costs for the use of personal transport, entertainment expenses, expenses for certain types of advertising, business trip expenses, interest on debt obligations, etc.);
The presence of expenses that are not recognized for tax purposes.
These, in particular, include social expenses, certain types of remuneration and bonuses for employees, payment of travel vouchers for employees, financial assistance, etc.
Permanent negative differences that lead to the emergence of permanent tax assets, reduce the current income tax of the reporting period relative to the conditional tax and, in particular, are formed due to the presence of:
Income that is not taken into account for tax purposes
(Article 251 of the Tax Code), for example, income in the form of property received
free of charge, if the authorized (share) capital (fund) of the receiving party consists of more than 50% of the contribution (share) of the transferring organization, interest received from the budget for late tax refund;
Expenses not recognized for accounting purposes, but
recognized for tax purposes. Since the accountant is
Russian standards are much more liberal than tax law.
legislation, there are very few expenses that would be recognized in tax accounting and not recognized in accounting.
Deferred tax assets, which arise as a result of temporary deductible differences, increase the current income tax of the reporting period relative to the conditional tax, but lead to a decrease in income tax payable in the following
212 L- Short-term financial policy
Periods. Temporary deductible differences, in particular, are formed due to:
Prepayments for products sold, as well as receipts
deferment of payments for purchased goods (works, services)
under the cash method for profit tax purposes;
Exceeding the amount of depreciation accrued for accounting purposes
Galter accounting, depreciation amounts accrued for the purposes
determination of the taxable base for income tax;
Carrying forward various types of losses to the future, in particular
losses from core activities, from sales
depreciable property, from operations on assignment of rights
requirements for the activities of service industries and
farms. The taxpayer has the right to transfer
loss for the future for a number of years subsequent to that
the tax period in which this loss was incurred;
Excessive payment of income tax to the budget, etc.
Deferred tax liabilities reduce the current income tax of the reporting period relative to the conditional tax, but lead to an increase in income tax payable in subsequent periods. Deferred tax liabilities are beneficial to an organization because they help increase financial results. This is true even taking into account the fact that temporary taxable differences lead to an increase in tax payments in subsequent periods, since the opportunity to obtain a “deferment” on tax payments is beneficial to the organization. Deferred tax liabilities arise from taxable temporary differences that arise as a result of:
Recognition of revenue from the sale of products (goods, works,
services) and interest income for cash taxation
method (upon subsequent payment);
Exceeding the amount of depreciation accrued for purposes
determining the taxable base for income tax,
depreciation amounts accrued for accounting purposes
accounting, due to the use of different methods and methods of
depreciation figures;
Use of bonus depreciation in tax accounting.
The presence of deferred expenses, which are in the tax
accounting are immediately written off to financial results;
Write off indirect expenses directly to financial results
you are in tax accounting;
Deferments or installments for the payment of income tax.
The impact of permanent and deferred tax assets and liabilities on the financial performance of the organization is presented in table. 5.22.
 |
214 II. Short-term financial policy
From the point of view of tax payments, it is beneficial for an organization if permanent tax assets and deferred tax liabilities are higher than permanent tax liabilities and deferred tax assets. In addition, it is beneficial for an organization to use legal methods of tax optimization, even if they lead to deferred taxes and complicate the work of the accounting department: this indicates that the priorities in the organization are set correctly - it is more important to save tax payments, rather than the labor costs of accounting employees.
For the final assessment of the ratio of conditional and current taxes and to clarify the reasons for the difference between these two indicators, it is calculated conditional income tax. The indicator can be calculated by adjusting the current income tax:
Well= N t- PNO + PNA - SHE + IT.
A positive value of the indicator indicates that the organization’s actual income tax payments are higher than the conditional ones calculated on the basis of accounting profit. This is unprofitable for the organization and is due to the fact that the sum of permanent tax liabilities and deferred tax assets exceeds the sum of permanent tax assets and deferred tax liabilities.
When analyzing the tax burden based on financial reporting data, it is necessary to take into account one more aspect: the impact of tax optimization methods on the reliability of financial reporting indicators. The use of tax optimization methods leads to a distortion of many indicators of an organization’s performance, in particular to an underestimation of tax bases and an overestimation of some expenses, which subsequently affects the overall assessment of the organization’s activities (Table 5.23).
Analysis of the situation. The assessment of tax payments of XYZ OJSC was carried out on the basis of financial statements; the initial data are given in table. 5.24.
In general, the organization’s tax payments increase significantly, in particular, the funds allocated for settlements of taxes and fees have increased significantly. In addition, the organization maintains its fiscal debt at a fairly low level, which deserves a positive assessment. However, it is impossible to draw reasonable conclusions about the tax burden without linking it with the organization’s performance indicators. For further calculation and analysis of the tax burden, additional indicators are needed (Table 5.25).
 |
215 II. Short-term financial policy
Table 5.24. Initial data for analysis
Analysis and assessment of enterprise taxation is an important element in the tax management system. Its content is to study the impact of taxes on the financial position of an enterprise, study the processes of taxation of an enterprise in connection and interdependence with various indicators of financial and economic activity. The study of enterprise taxation is based on a systematic approach, which makes it possible to justify the choice of tax accounting schemes, methods of minimizing taxes from the standpoint of their economic feasibility, and to implement in practice the strategy of optimal enterprise management.
Any decisions in the field of investment, scientific and technical policy of an enterprise, changes in the range of products, replacement of sales markets and other fundamental measures require anticipation of possible tax consequences, since such decisions affect the sources of tax obligations, i.e. legal facts with which the legislator associates the obligation to pay taxes. Underestimating tax consequences can lead to unpredictable situations. However, it is important for an enterprise not only to know the size of upcoming tax payments in the event of possible changes in the indicators of its economic activity, but also to do everything in its power to achieve such economic indicators of activity that ensure its optimal taxation. In this sense, tax analysis acts as a kind of regulator of the interests of production and taxation. His actions are based on knowledge of the factors of entrepreneurial economic activity that generate objects of taxation and, as a consequence, the tax base, the ability to determine their impact on the amount of taxes (tax burden), which allows achieving an optimal balance between the prospect of expanding the tax base and the resulting changes in tax obligations , to achieve a balance between the interests of production and taxation, without violating tax laws.
The first stage of tax burden analysis, which allows us to further develop the main provisions of the tax payment management policy, includes an analysis of absolute indicators. This analysis begins with an assessment of the revenue structure by its tax-intensive and non-tax-intensive components.
Thus, a non-tax-intensive structure of revenue will be one in which material costs, other costs, depreciation of intangible assets and fixed assets predominate, and profit and labor costs are insignificant.
Table 1.3 - Characteristics of the revenue structure by tax-intensive and non-tax-intensive elements
|
Revenue structure |
The impact of changes in the revenue structure on the amount of tax bases and obligations of the organization |
Characteristics of the revenue structure in terms of tax intensity |
||
|
Expenses for ordinary activities (cost and sales expenses) |
Variable costs |
Material costs |
An increase in the share of material costs in the revenue structure leads to an increase in the amount of money for VAT reimbursement from the budget, as well as a decrease in taxable profit, which entails a decrease in income tax payments. |
Non-tax-intensive |
|
Fixed costs |
Amortization of intangible assets |
An increase in the share of accrued depreciation in the revenue structure reduces taxable profit, which entails a reduction in income tax payments. |
Non-tax-intensive |
|
|
Depreciation of fixed assets |
Choosing a method for calculating depreciation and increasing its share in the revenue structure will lead to a decrease in the average annual residual value of fixed assets, which will entail a reduction in property tax payments. |
Non-tax-intensive |
||
|
Other costs |
An increase in the share of other costs in the revenue structure leads to a decrease in taxable profit, which entails a decrease in income tax payments. |
Non-tax-intensive |
||
|
Income from ordinary activities (less expenses from ordinary activities) |
Revenue from sales |
An increase in the share of profit from sales in the revenue structure leads to an increase in taxable profit, which entails an increase in income tax payments. |
Tax-intensive |
Thus, analysis of the structure of revenue by tax-intensive and non-tax-intensive components allows us to determine by what principles tax planning is carried out in an organization.
Next, a comparative analysis of the dynamics of the main economic indicators of the organization is carried out, i.e. tax bases and its tax payments, including an analysis of the structure of taxes paid, which allows us to assess the effectiveness of tax payment management. Thus, an effective tax policy will correspond to an increase in tax bases with a slightly slower increase in tax payments.
At the same time, in the context of main taxes, tax payments have the following structure:
income tax;
value added tax;
property tax;
other taxes.
It should be noted that tax payments will not include insurance premiums, which have lost their tax component since 2010, and personal income tax. Despite the fact that some authors take into account personal income tax when calculating the tax burden, in this work this is not considered appropriate, since the organization acts as a tax agent when calculating and paying it.
At this stage, we should separately highlight the analysis of income tax calculations, which allows us to assess the effectiveness of tax planning, as well as the completeness and effectiveness of using the possibilities of legal tax optimization in the organization’s activities (Table 1.4).
Table 1.4 - Indicators used to analyze income tax calculations
|
Indicator name |
Calculation method |
Comment |
|
Current income tax |
Np = t * Pd + PNO - PNA + ONA1 - ONA2 - ONO1 + ONO2, where Np is the current income tax, thousand rubles; t - profit tax rate, %; Pd - profit before tax, thousand rubles; PNO - permanent tax obligations, thousand rubles; PNA - permanent tax assets, thousand rubles; ONA1 - deferred tax assets arising in the current reporting period, thousand rubles; ONA2 -- deferred tax assets repaid in the current reporting period, thousand rubles; ONO1 -- deferred tax liabilities arising in the current reporting period, thousand rubles; ONO2 -- deferred tax liabilities repaid in the current reporting period, thousand rubles. |
This formula characterizes the relationship between the current and conditional income taxes. |
|
Taxable income |
Pn = Pd + Rp+ - Rp- + Rvv - Rvn, where Mon is taxable profit, thousand rubles; Рп+ - constant positive difference, thousand rubles; Рп- - constant negative difference, thousand rubles; Rvv - temporary deductible difference, thousand rubles; Rvn - temporary taxable difference, thousand rubles. |
The calculation is obtained by dividing the left and right sides of the methodology for calculating the current income tax by the tax rate. |
|
Conditional income tax |
Well = Np - PNO + PNA - SHE + IT, where Nu is the conditional income tax, thousand rubles. |
Determined through an adjustment to the current income tax. |
|
Deviation of the current income tax from the conditional one. |
He = (Nt - Well): Well *100%, where He is the deviation of the current income tax from the conditional one, thousand rubles. |
A positive value of the indicator indicates that the organization’s actual income tax payments are higher than the conventional ones. This |
Comparison of conditional and current tax allows you to assess how beneficial the relationship between these values is for the organization. It is beneficial for the organization if the conditional tax exceeds the current one, since the excess is a consequence of the fact that the organization pays a relatively lower tax on the received accounting profit. The reason for such a favorable circumstance for the organization may be the presence of permanent tax assets and deferred tax liabilities (Table 1.5).
Table 1.5 - Indicators influencing the deviation of the current income tax from the conditional one
|
Characteristics of the indicator |
Factors influencing its occurrence |
|
Permanent positive differences, which result in permanent tax liabilities, increase the current income tax of the reporting period relative to the conditional tax. |
adjustments of tax revenues in accordance with Art. 40 Tax Code of the Russian Federation. In this case, accounting income is lower than tax income, since transaction prices for tax purposes increase in accordance with market prices; the excess of actual expenses taken into account when forming accounting profits, expenses accepted for tax purposes, for which restrictions on expenses are provided (costs of voluntary insurance of employees, costs of research expenses, costs of compensation for the use of personal transport, entertainment expenses, expenses for certain types of advertising, business trip expenses, interest on debt obligations, etc.); the presence of expenses that are not recognized for tax purposes (certain types of remuneration and bonuses to employees, payment of vouchers to employees, financial assistance, etc.). |
|
Permanent negative differences, which lead to permanent tax assets, reduce the current income tax of the reporting period relative to the conditional tax. |
income that is not taken into account for tax purposes Art. 251 of the Tax Code of the Russian Federation, for example, income in the form of property received free of charge; expenses not recognized for the purpose accounting, but recognized for tax purposes. |
|
Deferred tax assets that arise from deductible temporary differences increase the current income tax of the reporting period relative to the deemed tax. |
application of different methods of recognition of commercial and administrative expenses in the cost of sold products, goods, works, services in the reporting period for accounting and tax purposes; loss carried forward, not used to reduce income tax in the reporting period, but which will be accepted for tax purposes in subsequent reporting periods, unless otherwise provided by the legislation of the Russian Federation on taxes and fees; application, in the case of the sale of fixed assets, of different rules for recognizing for accounting and tax purposes the residual value of fixed assets and expenses associated with their sale; the presence of accounts payable for purchased goods when using the cash method of determining income and expenses for tax purposes, and for accounting purposes - based on the assumption of temporary certainty of the facts of economic activity. |
|
Deferred tax liabilities reduce the current income tax of the reporting period relative to the contingent tax, but lead to an increase in the tax payable in subsequent periods. Deferred tax liabilities are beneficial to an organization because they help increase financial results. This is true even taking into account the fact that temporary taxable differences lead to increased tax payments in subsequent periods, since the opportunity to obtain a “deferment” on tax payments is beneficial |
application of different methods of calculating depreciation for accounting purposes and purposes of determining income tax; recognition of revenue from the sale of products in the form of income from ordinary activities of the reporting period, as well as recognition of interest income for accounting purposes based on the assumption of temporary certainty of the facts of economic activity, and for tax purposes - on a cash basis; application of different rules for reflecting interest paid |
From the point of view of tax payments, it is beneficial for an organization if permanent tax assets and deferred tax liabilities are higher than permanent tax liabilities and deferred tax assets. In addition, it is beneficial for an organization to use legal tax optimization methods, even if they lead to deferred taxes and complicate the work of accounting.
This stage of tax burden analysis ends with an assessment of the impact of tax payments on the financial results of the organization, since the organization’s managers are primarily interested in issues of increasing income.
At the second stage, the tax burden is assessed using relative indicators. For these purposes, the tax burden means the ratio of tax payments to financial results. Also, the tax burden can be calculated per unit of physical indicator, for example, per employee, per 1 sq. m area.
It is advisable to compare the tax burden indicators calculated in relation to the financial and non-financial indicators of the enterprise with industry indicators, taking into account the regional characteristics of the taxation of the organization.
For a comparative analysis of the tax burden on an organization, you can use the methodology for calculating “reference” values taking into account indicators of the revenue structure (Table 1.6).
Based on the results of calculating the relative indicators of the tax burden, the directions of tax policy are determined (Table 1.7). The reasons for a significant reduction in the relative tax payments of an organization compared to the “reference” or industry average burden should be carefully studied to assess the safety of the tax optimization methods used.
Table 1.6 - Relative indicators used to assess the tax burden of an organization
|
Indicator name |
Methodology for calculating the indicator |
Methodology for calculating the “reference” value |
Explanation |
|
1. Tax burden on the total income of the organization |
Нв1 = Н/(В+Др) * 100%, where Нв1 is the tax burden on the total income of the organization, %; N - total tax payments to the budget, thousand rubles; B - revenue (net) from the sale of products, thousand rubles; DPR - other income, thousand rubles. |
Absent |
Нв2 = Н/В *100%, |
Nv2e = Stnp * dnp + Stnds * (1-dnds), where Nv2e is the “reference” tax burden on revenue, %; Stnp - profit tax rate, %; dnp - share of taxable profit in the revenue structure, units; Stnds - value added tax rate, %; dvt - share of non-tax-intensive elements in the revenue structure, units. |
Used to estimate the total tax burden |
|
3. Tax burden on accrued added value |
VAT1 = N / (V - MZ) * 100%, where VAT1 is the tax burden on accrued added value, %; MZ - material costs, thousand rubles. |
Absent |
Used to estimate the total tax burden |
Table 1.7 - Type of tax policy of a small enterprise and the composition of control measures within the policy
|
Policy type |
Possible set of control measures on the object |
||
|
Perfect |
The policy is built within the framework of accounting, the use of direct benefits and the capabilities of the current taxation system, if necessary, a high professional level of the chief accountant and the organization of the accounting service. The most complex issues are considered with the assistance of tax consultants. With insignificant turnover, it is possible to conclude contracts with auditing firms for accounting services when removing the accounting service from the staff |
||
|
Conservative |
Tax policy is considered as an obligatory element of the general financial policy, the development and implementation of which involves specialists allocated to a special service. To resolve the most complex issues and optimize tax schemes, a subscription service agreement is concluded with an audit firm. |
||
|
Compromise |
Tax policy implies strategic planning of activities in all areas, including forecasting the amounts of tax withdrawals. There is constant work with tax lawyers and consultants. The state of the taxation system is systematically monitored in its relationship with business performance. |
||
|
Aggressive |
The issue of changing tax jurisdiction or reprofiling activities is being considered. |
The final stage is the analysis of the organization's debts for taxes and fees based on an assessment of total tax assets and liabilities, their share in the assets and liabilities of the balance sheet.
A positive tax position (the difference between tax assets and liabilities) is unprofitable for the organization, since it represents a free loan to the state, while a negative one is accordingly beneficial. Therefore, significant tax assets can be considered a sign of ineffective management of tax payments. In addition, the item “VAT on acquired assets” is characterized by low liquidity and therefore worsens the quality of the organization’s current assets.
The article “VAT on acquired values” includes:
VAT amounts on purchased assets that are not properly documented in invoices from suppliers, contractors, and other creditors;
unpaid amounts of VAT on purchased valuables in relation to the customs value of goods imported into the territory of the Russian Federation;
VAT amounts on acquired but not accepted for accounting fixed assets and intangible assets;
amounts of VAT on goods (work, services) used for the production and sale of goods taxed at a rate of 0%, but for which the tax authority has not yet made a decision on reimbursement.
Thus, summarizing the above, we can draw the following conclusion that in the process of analyzing the tax burden over a number of years, statistical data on the organization is generated, which allows the management of a given enterprise to decide on the need to implement tax optimization measures. That is, one of the main goals of determining the level of tax burden is to use the information obtained in tax planning.
G.A. Kurbatov,
senior tax manager
KPMG Russia and CIS department
A.A. Vaqar,
senior tax consultant
KPMG Russia and CIS department
The global financial crisis, unfortunately, did not spare Russia. Non-payments for shipped products have become an everyday reality for Russian organizations. In addition to economic risks, buyer insolvency has tax consequences.
What to do if the buyer does not pay, but taxes must be paid?
Many companies, especially large ones, use the accrual method to determine when revenues and expenses are recognized. At the same time, at the end of the tax period, the supplier company is obliged to recognize for the purposes of income tax and VAT the income from the shipped products, regardless of whether the buyer paid for the specified products or not. At the same time, taxes must be paid to the budget in money. But how to pay if funds have not been received from the buyer?
If the buyer delays payment for shipped products and does not pay the supplier in the reporting (tax) period when the goods are received, the supplier company is obliged to recognize receivables for goods shipped but not yet paid for as income for tax purposes. What if such buyers are the majority? In a crisis situation, not only individual companies, but also entire sectors of the economy found themselves in this situation. It can take years to sue a defaulter, but taxes still need to be assessed and paid. What should you do to avoid constantly paying taxes “for yourself and for that guy”?
Russian legislation provides companies with several tools that allow them to balance the tax burden of an enterprise when the solvency of buyers decreases. Such tools, in our opinion, can be:
Creation of reserves for doubtful debts;
Assignment of the right of claim;
Novation of debt;
Reorganization of the company and creation of a separate legal entity operating under the simplified taxation system (STS);
Deferment, installment plan, investment tax credit;
Tax holidays.
Let's consider their advantages and disadvantages.
Creation of a reserve for doubtful debts
The Tax Code of the Russian Federation (clause 3 of Article 266) provides that provisions for doubtful debts are recognized as expenses that reduce the tax base for income tax. At the same time, the possibility of their creation should be enshrined in the accounting policies of the organization.
Doubtful debt is any debt to the taxpayer arising in connection with the sale of goods, performance of work, provision of services, if it is not repaid within the time period established by the agreement and is not secured by a pledge, surety, or bank guarantee.
By creating a reserve for doubtful debts, the company includes in expenses that reduce the tax base for income tax the amount of debt owed by customers with overdue payments, thereby reducing current income tax payments, postponing them to a later date, and saving its own working capital. When the buyer pays the overdue debt, the amount received will be taken into account as income for income tax purposes.
Along with the undeniable advantages, creating a reserve for doubtful debts has a significant drawback - the Tax Code of the Russian Federation provides for the creation of a reserve only for income tax purposes, and in case of non-payment, the supplier company will still be obliged to calculate and pay VAT to the budget.
Assignment of the right of claim
The problem of non-payments and balanced management of the tax burden of an enterprise can be solved by assigning the right of claim. This possibility is provided for in Art. 389 of the Civil Code of the Russian Federation by concluding an assignment agreement (clause 1 of Article 389).
The conclusion of an assignment agreement allows you to receive “real money” instead of “virtual” receivables with uncertain prospects of turning into real money. In fact, the seller assigns (sells) the buyer's debt to a third party, receiving funds. In this case, the insolvent buyer remains indebted to the third party for the corresponding amount.
The disadvantages of this method include the fact that overdue debt in practice, as a rule, is sold below par, which can harm the economic interests of the supplier company.
The initial assignment of debt is subject to income tax and VAT if the amount of funds received exceeds the amount of the assigned debt. However, in practice such situations are extremely rare.
Novation
The problem of non-payments for shipped products and balanced management of the enterprise’s tax burden can be solved by terminating obligations under the supply contract and concluding a novation agreement on terms acceptable to both parties (clause 1 of Article 414 of the Civil Code of the Russian Federation).
Thus, companies can, for example, agree that the debt for shipped products is treated as a loan with new repayment periods established and the corresponding interest paid for the period of use of the funds. Thus, the debtor will pay part of his debt at once, and the creditor-supplier will provide him with an installment plan. As a result, the lender will be able to use the funds received from the buyer to repay the debt to the budget for VAT and income tax.
However, this will not solve all the problems that have arisen in this situation, since it will lead to a decrease in the company’s own working capital and an extension of the turnover cycle of its capital. Transferring debt for shipped products into a loan has no tax consequences, i.e. does not lead to additional tax payments to the budget.
Offsetting
This method of solving the problem of non-payments and balanced management of the tax burden of an enterprise is applicable if there is mutual debt between the supplier and the buyer (Article 410 of the Civil Code of the Russian Federation). The offset of counterclaims between the supplier and the buyer does not result in the supplier receiving funds from the buyer. However, the supplier may be freed up funds intended to repay the debt to the buyer under counter-obligations. These funds can be used to pay taxes to the budget. Since offsetting pays off the obligations of the buyer to the supplier and the supplier to the buyer in an equal amount, no additional income arises for tax purposes.
When offsetting counterclaims, the VAT amounts presented to the buyer upon shipment (when carrying out transactions subject to VAT), according to the law, must be paid by the buyer to the supplier in cash. In fact, if both debts arose from transactions subject to VAT, the same amounts of money will be transferred from the buyer to the supplier and from the supplier to the buyer, which will not lead to a decrease in their liquid assets.
Transfer of certain types of activities to the simplified tax system
The problem of non-payments and balanced management of the tax burden of an enterprise can be solved by reorganizing and transferring certain types of activities of the enterprise (those in which the risks of non-payment have increased due to the crisis) into newly created legal entities that apply the simplified tax system.
Companies using the simplified tax system use the cash method of recognizing income and expenses, and thus, in the event of non-payment for shipped products, there is no obligation to pay taxes (clause 1 of article 346.17 of the Tax Code of the Russian Federation).
A significant advantage of using the simplified tax system is also tax savings. Companies using the simplified tax system are exempt from the obligation to pay corporate income tax (with the exception of tax paid on income taxed at the tax rates provided for in paragraphs 3 and 4 of Article 284 of the Tax Code of the Russian Federation), corporate property tax and the unified social tax. These taxes are being replaced by a single tax levied on income at a rate of 6% or on income reduced by the amount of expenses at a rate of 15% (Article 346.20 of the Tax Code of the Russian Federation).
Companies that apply the simplified tax system are not recognized as VAT payers, with the exception of the tax payable when importing goods into the customs territory of Russia, as well as the tax paid in accordance with Art. 174.1 of the Tax Code of the Russian Federation (clause 2 of Article 346.11 of the Tax Code of the Russian Federation).
The disadvantages of this financial instrument include the fact that the Tax Code of the Russian Federation limits the right to apply the simplified tax system by type of activity. In particular, the following do not have the right to apply the simplified tax system: organizations with branches and (or) representative offices; banks; organizations and individual entrepreneurs engaged in the production of excisable goods, as well as the extraction and sale of minerals; foreign organizations, etc. (clause 3 of article 346.12 of the Tax Code of the Russian Federation). There is a limit on the amount of revenue at which the taxpayer retains the right to apply the simplified tax system. In accordance with the amendments made to the Tax Code of the Russian Federation by Federal Law No. 204-FZ of July 19, 2009, from January 1, 2010 to December 31, 2012, the maximum amount of income from sales should not exceed 60 million rubles. per year in the absence of a deflator coefficient, and from January 1 to December 31, 2013, an “income limit” is applied in the amount that, taking into account indexation, was in force in 2009, i.e. 30.76 million rubles. (20 million rubles x 1.538). The amount of net assets is also limited. The average number of personnel for the tax period should not exceed 100 people. In addition, there are restrictions on the ownership structure of the company using the simplified tax system. The share of participation of legal entities in such a company should not exceed 25%.
From a practical point of view, the fact that a company using the simplified tax system is not a VAT payer can turn from an advantage into a disadvantage when products are sold not to end consumers, but to intermediaries. In this situation, the intermediary company will not be able to refund the “input” VAT and will pay tax on the entire cost of products sold further.
Deferment, installment plan, investment tax credit
The use of such methods of managing the tax burden as deferment, installment plan and investment tax credit is provided for in Chapter. 9 of the Tax Code of the Russian Federation. From an economic point of view, they are a loan provided by tax authorities to enterprises, but under different conditions.
A deferment is an interest-free loan where a company is given the right to defer payment of its tax obligations to another period.
The installment plan gives the company the opportunity to pay the amount of tax debt not all at once, but in parts. However, in both cases, under certain conditions, according to the Tax Code of the Russian Federation, interest will be accrued for the deferment or installment plan.
The investment tax credit already defines its essence in its name. It provides companies with the opportunity to reduce tax payments over a certain period of time, and at the end of the period, pay this amount with interest accrued on it.
In the event of non-payment of shipped products by the buyer, the use of these financial instruments by the supplier allows them to pay their tax obligations after receiving payment from the supplier and not use their own working capital to pay taxes. However, there are also disadvantages. Firstly, this will lead to additional expenses in the form of interest for using a deferment, installment plan or investment tax credit. Secondly, the legislator limited the list of grounds on which a deferment, installment plan or investment tax credit can be granted. And thirdly, in practice the use of these financial instruments is limited.
Tax holidays
Theoretically, the problem of non-payments and balanced management of the tax burden of an enterprise is less relevant where there are tax holidays, and these are, as a rule, the territories of special economic zones (for example, Kaliningrad, Magadan, etc.).
Companies operating within such a territory receive certain benefits that provide exemption from paying one or more taxes for a specific period if certain conditions are met. Therefore, delays in payments by counterparties will not affect the payment of taxes.
On the other hand, the use of this method of avoiding negative tax consequences is of little use due to the limited list of grounds for registration as a participant in a special economic zone*1.
*1 Read more about the possibilities of Russian special economic zones in the article by R.A. Mitrofanova on p. 138. - Approx. ed.
conclusions
Thus, the tax and civil legislation of the Russian Federation provides some opportunities for minimizing the negative consequences of non-payments and offers an “arsenal” of methods for managing the tax burden of an enterprise.
Creating reserves for doubtful debts allows you to reduce the tax base of an enterprise for income tax by the amount of doubtful debts in the current period, without waiting for the statute of limitations to expire. The disadvantage is the inability to create reserves for VAT.
Assignment of the right of claim is another relevant method of managing the tax burden of an enterprise in conditions of non-payment. This method allows you to receive “real” money instead of debts. Its disadvantage is the following fact: overdue debt, as a rule, is sold at a discount, sometimes with a significant one, which leads to a decrease in profits.
Novation of debt allows you to save your own working capital. The disadvantage of this method is the extension of the turnover period of own working capital.
Offsetting solves problems in the presence of counterclaims. This situation is possible in intra-group settlements. But in this case, VAT would still have to be paid by all parties to the offset.
Reorganization of an enterprise and the transfer of certain types of its activities into newly created legal entities that apply the simplified tax system makes it possible to switch from the accrual method to the cash method of recognizing income and expenses. At the same time, the company will receive significant tax savings. However, the Tax Code of the Russian Federation provides for a number of restrictions for the transition to the simplified tax system, related to the types of activities, the amount of revenue and the value of net assets, the number of personnel and the ownership structure. The use of the simplified tax system is optimal when selling products to end consumers, but when selling products to intermediaries, problems may arise with VAT reimbursement by the purchasing company.
Deferment, installment plans, investment tax credit and tax holidays in practice remain more exotic. However, theoretically, postponing the deadline for paying tax obligations to future periods can also be considered as help.
The tools for managing tax payments with increasing insolvency of buyers analyzed in this article are based on the norms of current legislation and are most often used in practice, as a rule, after the products have been shipped and it has become clear that the buyer is insolvent. At the same time, there are other legal tools for managing tax payments that are used before making transactions with insolvent buyers - preliminary structuring of transactions (planning financial and economic activities), identifying sources of raising funds (intra-group loans, etc.), including interim and intermediary companies with the aim of shifting economic risks from the manufacturer to intermediaries, including mandatory prepayment in the terms of contracts, etc.