Tax payment status in the payment order. Payer status in payment order

Another surprise has been prepared for citizens insurance premiums 2017: the payer status “14” in the payment order causes many problems and difficulties. When filling out field 101, you must indicate the code “01”. If you indicate code “14” as the payment status, the bank will not accept the payment document. Why? Because this is considered a violation of the requirements of the Ministry of Finance, which were issued in the one hundred and seventh order. This information was obtained from a letter from the central bank, which it published in February.

And this is despite the fact that it was tax officials who mandatory established that all organizations and individual enterprises that contribute funds to insurance premiums must indicate payer status “14” in the payment order. Consequently, the question arises, how to correctly pay insurance premiums in 2017, if banks do not allow payer status “14”, and tax authorities strongly recommend indicating it?

On the third of February this year, the fiscal service issued another document that advises enterprises and companies to indicate the value “01” in field 101. This decision was justified by the need for banks to reorient software in order to accept new status payer of insurance premiums “14”. This work may take about six months, but until it is completed, the use of the new code value will have to be limited.

But the central bank's comments suggest that the problem in the perception of the new value lies far from the need to reorient programs. If field “101” contains the mark “14” and is a combination with the identification number of the legal entity in the details, and a zero value is indicated in the code column, if the organization does not have a UIN, then this will be a violation of order one hundred and seven. Therefore, such a status as an insurance premium payer cannot be accepted by banking organizations. Consequently, insurance premiums cannot be paid in 2017 if the document contains code “14”.

• “01” – indicate legal entities that paid any funds to any individual or group of individuals;
• “09” – indicated by individual entrepreneurs;
• “10” – must be entered by notaries who conduct private practice;
• “11” – indicated by lawyers who have established a law office;
• “12” – contributed by the heads of peasant and farm enterprises;
• “13” – indicate individuals.

Carolina Emelyanova

The transfer of administration of insurance premiums to the Federal Tax Service has raised many questions. One of the most relevant: what is the payer status for payment of insurance premiums from 2017 to indicate in field 101 of the payment order? We previously published material dedicated to issues filling out payment orders for insurance premiums in 2017. And here we will only touch on changes in filling out field 101.

It is known that the rules for filling out field 101 in a payment order are regulated by Appendix No. 5 to Order No. 107n of the Ministry of Finance of the Russian Federation. But acting on this moment the edition of this application does not contain a status that could undoubtedly be applied to the policyholder transferring contributions to the Federal Tax Service. Let us remind you that before the transfer of administration of insurance premiums to the Federal Tax Service, it was necessary to indicate code “08” in all cases in the payment order for payment of insurance premiums.

In turn, in 2016, the Ministry of Finance of the Russian Federation published a draft order “On amendments to the order of the Ministry of Finance of the Russian Federation No. 107n.” This document states that when transferring insurance premiums by legal entities, code “01” must be indicated in field 101. Individual entrepreneurs paying insurance premiums “for themselves” must indicate the payer code “09”, individual entrepreneurs paying insurance premiums for employees, must indicate payer status “14”.

But this project The order has not yet entered into force. Therefore, what the payer’s status should be in a payment order in 2017 is not entirely clear.

However, there is still no official clarification on this topic. In this regard, we can only rely on our own logical thinking, in the hope that it coincides with the thinking of the people who will administer these payments.

Meanwhile, on thematic forums on the Internet, accountants express three points of view on what status should be indicated in field 101. We bring each of them to the attention of readers.

According to one opinion, individual entrepreneurs, when paying contributions for themselves, should put code “09” in field 101, and when paying contributions for employees, code “14”; organizations - code “01”. This opinion is based on the fact that the administration of insurance premiums has been transferred to the tax authorities, which, according to supporters of this point of view, makes it possible to put an equal sign between policyholders and taxpayers. The problem with this decision is that the current version of the Tax Code separates the concepts of “payer of insurance premiums” and “taxpayer”.

This status was applied when transferring insurance premiums in past years, and, according to a number of experts, should be applied now. In particular, payment orders with this particular payer status are accepted by Sberbank Online, rejecting payment orders that indicate other statuses. Let us remind you that status “08” is intended for individual entrepreneurs and organizations that transfer insurance contributions to the budget of the Russian Federation. The problem is that several regional branches of the Federal Tax Service of the Russian Federation gave official answers to policyholders the day before with a recommendation to indicate a different payer status, which is discussed below.

This status means a taxpayer making payments to individuals. It would seem that it is completely unsuitable for the case under consideration. However, as mentioned above, several local tax authorities recommended using this particular code.

As we can see, at the moment it is impossible to say with certainty what the payer’s status should be in the payment order for insurance premiums in 2017. Without a doubt, we can only talk about the status of the payer when paying contributions “for injuries”. Their administration was not transferred to the Federal Tax Service, but remained under the control of the FSS. Therefore, in this case, it is necessary to indicate unambiguously, as in previous years, the code “08”.

As for “medical” and “pension” contributions, the possibility of error remains when indicating any of the statuses discussed above.

Meanwhile, the practice of past years shows that Federal Tax Service inspectors count payments with an incorrectly indicated payer status. The main thing is that the details of the recipient and the KBK, which changed in 2017, are indicated correctly. If you have already made the payment, and after the publication of official clarifications it turns out that the payer status in the payment order in 2017 is indicated incorrectly, in order to fully protect yourself from arrears in insurance premiums, it is worth submitting an application to clarify the payment (based on the letter of the Federal Tax Service of the Russian Federation No. SA -4-7 /19125). A copy of the payment order must be attached to the application.

Update 02/08/2017 - clarification of the Federal Tax Service on the issue of payer status

Some regional Federal Tax Service Inspectors have sent out explanations to policyholders regarding filling out payment orders for the payment of insurance premiums in 2017. They, along with samples of filling out payment slips, are contained in the following document:

According to the document, the payer status is indicated as follows:

• Status 01 - indicated when paying insurance premiums by a legal entity;
• Status 09 - indicated when paying insurance premiums by an individual entrepreneur;
• Status 10 - indicated when paying insurance premiums by a notary engaged in private practice;
• Status 11 - indicated when paying insurance premiums by the lawyer who established the law office;
• Status 12 - indicated when paying insurance premiums by the head of a peasant (farm) enterprise;
• Status 13 - indicated when paying insurance premiums for employees an individual(not being an individual entrepreneur).

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All insurance premiums are paid using a document called a payment order, the execution of which differs depending on the type of insurance and the status of the applicant. In 2019, this type of payment underwent a number of innovations that changed the process of filling out the form itself.

So, if until the end of 2019 the recipients of the order were private funds - the Social Insurance Fund and the Pension Fund of the Russian Federation, then since the beginning of this year almost all payments are sent to the Federal Tax Authority. The column regarding the payer status has also changed, which is important to consider when sending a contribution, otherwise the funds may not be accepted by the recipient.

The new status of the payer in the payment order in 2019 has not yet been fully determined, so a lot of disputes and misunderstandings are developing around it. What exactly should now be written in the column about the status of the sender of funds? What happens if the status is incorrectly specified? And what other changes to the payment document should you know about?

Starting in January 2019, some changes were introduced to the process of issuing orders for sending insurance premiums. So, if until the end of last year the recipients of contributions were the Social Insurance Fund and the Pension Fund of the Russian Federation, now insurance funds are sent to the Federal Tax Service.

All types of contributions are sent to the Federal Tax Service, with the exception of workplace injury insurance. This type of insurance is still sent to private funds with which one or another organization or individual entrepreneur cooperates.

Such contributions include:

• mandatory pension insurance for individual entrepreneurs and individuals;
• Compulsory medical insurance physical individuals and individual entrepreneurs;
• contributions for temporary disability insurance.

Changes in the recipient column are not the only innovations introduced this year. The KBK codes have been updated, and the legal addresses of some banking institutions have also changed, which must be taken into account when filling out the document.

In addition, the details of the sender of the cash contribution have changed in the payment order, so when filling out the form for sending insurance funds, you need to be especially careful.

It is necessary to issue a payment order according to the new rules only if the contribution is made for the period starting from January 2019. If money is transferred for a previous unpaid period, for example, if there is a debt for last year, then you need to fill out the documentation as before.

However, when sending funds that should have been deposited before December 2019, you need to be careful when filling out the column about the address of the credit institution and its name. The fact is that some banking organizations have changed their details and, regardless of the period for which the contribution is transferred, a new address must be indicated.

Payment of insurance premiums is carried out by filling out a special order form. This type of document has a form established by law, so all tax and insurance payments must be made only with its help.

The payment order is filled out by the following persons:

The document for making this kind of payment consists of several forms that have more than fifty points, so when filling it out, payers make many mistakes, which most often manifests itself in confusion in the columns regarding the details of the recipient and the sender.

The form is filled out in accordance with the coding of payment deductions established by the tax authority. It is important to remember that all BCCs that were valid before 2019 are outdated and no longer apply. The exception is when sending a contribution for a previous unpaid period (before December 2019).

This year, changes have been made to the forms regarding the recipient, sender, tax coding and details of credit institutions. The remaining columns remain the same, so they are filled out the old fashioned way.

As for the status of the payer, these details are entered in field 101. To determine the sender of the contribution, there are several types of encodings, consisting of two digits, with the help of which the Federal Tax Service determines who exactly sent the funds and what type of payment the money transfer belongs to.

The need to determine the status of the sender arises only when the transfer of tax fees, insurance premiums and other obligatory payments established by the legislation of the Russian Federation is carried out. When a money transfer is made in favor of a counterparty, there is no need to fill out column 101.

The basic rules for processing insurance and tax payment orders are established and approved by the Order of the Ministry of Finance of Russia of 2013. Despite the fact that many changes have been made to the document itself over a long period, the filling out process still remains the same.

The only thing worth paying attention to when drawing up the document is that starting from the current year, pay mandatory types of contributions instead of physical ones. persons can now be intermediaries, which include:

• organizations and enterprises;
• other individuals.

Regardless of who fills out the payment document, the rules for completing the form remain the same.

From 2013 to the end of 2019, a single list of payment codes was compiled and agreed upon, which determine who exactly the sender is:

Based on the list provided above, it can be seen that now all insurance payments in the document are marked with number 08.

The status of the payer in the payment order in 2019 was subject to fundamental changes. Now there are much more codes for paying for compulsory insurance. On the one hand, this helps the Federal Tax Service determine the exact status of the sender, and on the other hand, it provokes confusion when filling out the form, especially if the payer has little knowledge of this issue.

Most often, misunderstandings arise when filling out the form to pay for the transfer of mandatory pension and medical benefits. insurance. The fact is that this type payments starting from the current year are processed in the same way as tax transfers. Accordingly, the payment encodings are the same - “01” for both compulsory medical insurance, compulsory medical insurance, and tax collection. The only difference is the BCC number and the purpose of the contribution itself.

In addition, this year additional statuses for senders of funds have appeared, such as transfers of insurance payments for other people, that is, money is sent by third parties. So, for example, if the form is prepared by the accounting department of an organization, then it is necessary to enter the code “29” in the appropriate column, and for simple individuals. persons - “30”.

In accordance with the changes that have occurred, all Individual entrepreneurs After the innovations that occurred at the beginning of the year, in order to pay mandatory insurance transfers, the status of the sender must be indicated by encoding:

If an individual entrepreneur acts as a tax agent and pays personal income tax for his employees, then the code “02” must be indicated in the status of the payment order. It was used before innovations and is not outdated to this day.

The information in field 101 is filled in in accordance with the status of the sender of funds, which is determined based on special numberings.

A detailed list of codes required when filling out a payment order in 2019:

If everything is less clear with the payer status encodings, then confusion often arises in the changed BCC numbers. It is important to remember that new BCCs were established for all payments made during 2019, so the use of old ones is simply unacceptable. If contributions are paid for last year's debts, then the old tax codes should be used.

Examples of the main BCCs when paying an insurance premium for the previous period and the current one:

As can be seen from the table above, before the changes, BCCs were indicated by the numbers 392, but after the innovations, the numbering changed - 182. The exception is the transfer of insurance premiums for occupational diseases and industrial accidents. This type of payment is transferred to private funds, so the BCC for them has not changed.

After the changes affecting the payer's status, cases of incorrect coding in a payment order began to become more frequent. What are the consequences of making such a mistake? Firstly, it should immediately be clarified that regardless of the correctness of the data indicated in column 101, the tax office will still accept the payment, but where exactly the funds will be distributed remains in question.

So, for example, if one accountant, when drawing up an order, indicates code 08, and another 01, then there is a high probability that the tax authorities will regard this as an error. In this case, arrears may arise regarding insurance premiums, since for payments in which different statuses are indicated, the Federal Tax Service distributes funds to separate personal accounts.

Payer status under code 08 can be accepted as not insurance premiums, but other obligatory payments. Because of this, the latter of them will be overpaid, and the former will begin to accumulate debt.

To avoid confusion and avoid debts on insurance premiums, after completing the payment document, you should write and send it to tax service a statement that clarifies the purpose of the payment, attaching a copy of the completed order.

Changes were made by Order of the Ministry of Finance of Russia dated 04/05/2017 No. 58n. For the current procedure for filling out payment orders, see.

In the order established by the Ministry of Finance of Russia (Appendix No. 5 to the Order), there is no clear answer to the question of which code to indicate in field 101. There were three filling options in the media:

• “01” - “taxpayer (payer of fees) - entity“by analogy with the payment of taxes and fees”;
• “08” - “payer - legal entity (individual entrepreneur, notary engaged in private practice, lawyer who established a law office, head of a peasant (farm) enterprise) carrying out the transfer Money for the payment of insurance premiums and other payments to the budget system of the Russian Federation";
• “14” - “taxpayer making payments to individuals.”

Simply and quickly generate payment orders for requests for payment of taxes, fees and contributions in the online reporting system Kontur.Extern:

In addition to the procedure for filling out a payment order, the letter from the Federal Tax Service, the Pension Fund of the Russian Federation and the Social Insurance Fund also addresses other issues. Among them:

• deadlines for payment of insurance premiums;
• forms for reporting (primary and updated);
• transfer of settlement balances and provision of certificates on the status of settlements for insurance premiums;
• transfer of decisions from the Pension Fund and the Social Insurance Fund to the Federal Tax Service.

If you have already paid contributions to the Federal Tax Service and indicated the code “01” or “08”, this does not mean that the payment will certainly be “lost” and the policyholder will have arrears. In practice, inspectors count payments with the correct information, even if they contain the “incorrect” payer status. To prevent all possible questions from tax authorities, clarify your payment in accordance with clause 7 of Art. Tax Code of the Russian Federation.

The year brought quite a significant change in the procedure for paying insurance premiums. If until now these payments were transferred to two separate funds - the Pension Fund of the Russian Federation and the Social Insurance Fund, then from now on the Federal Tax Service will be the manager of these receipts. It is to the tax office that contributions for pension, health and social insurance must be transferred. The only exception remains the so-called deductions for injuries: they, as before, will need to be transferred to social insurance. For all other payments, payers will have to master the new procedure for processing payment documents.

First of all, it is worth noting that the new details of the recipient of contributions, that is, the Federal Tax Service, are valid on a temporary basis, that is, they are applied from January 1, 2017. Thus, if we're talking about about transferring contributions for December or some of last year’s arrears in January, then you need to use them. Of course, when an employer fills out reports for last year for the Pension Fund and the Social Insurance Fund, it will be necessary to indicate in such a case the corresponding amount of debt as of the end of December. In the new consolidated report on contributions, which will need to be compiled based on the results of the 1st quarter, these transfers related to last year, but already paid to the Federal Tax Service, will be taken into account.

Since the Federal Tax Service will be the administrator of payments for contributions, all fields of the payment order relating to the recipient of the amount must be filled out in the same way as in the case of tax transfers. That is, in those fields where the PFR or FSS data previously appeared, the Federal Tax Service Inspectorate at the place of registration of the company or individual entrepreneur, its bank details, INN and KPP are indicated. We must remember that field 101 of the payment slip is also filled out in a new way. Payer status in the payment order in 2017, when paying insurance premiums, the Federal Tax Service ]]> recommends ]]> both organizations and individual entrepreneurs with employees to indicate code 14 - taxpayer making payments to individuals. Field 101 “payer status” for entrepreneurs and other individuals who pay contributions for themselves takes on a value depending on who is transferring them: individual entrepreneur – 09, notary – 10, lawyer – 11, head of peasant farm – 12. This applies to all insurance premiums , except for “injuries”. When transferring contributions for accident insurance, the previous value of field 101 – 08 is retained.

The situation with filling out the KBK field is somewhat more complicated. Naturally, from 2017, when paying contributions it is necessary to use the new BCC. Moreover, for the transfer of payments relating to the period until the end of 2016, one set of BCCs will be in effect, and for contributions in 2017 and beyond, another set will apply. And naturally, they will differ from the codes that were used in 2016.

For convenience, we present the main KBK-2017 for insurance premiums in a comparative table: