In accordance with the order of the DFSU, the regional branch of the DFS is directed to send inquiries to the farm enterprises that have overpayments and underpayments in the integrated payer card (IPC) as of July 1, 2018, according to the budget classification code 14010160 (VAT amounts remaining at the disposal of the company in accordance with Article 209 of the Tax Code )

Checking for such overpayments is possible in the e-office of the taxpayer in the section "State of settlements with the budget"

The purpose of sending such inquiries is to actually write off arrears or overpayments from the IPCs of the former special regimes, and in the future the DFSU intends to close the following payer cards.

The risks that have been expressed are:

  • that if the overpayment is canceled, the relevant amount under the CEA VAT formula will be written off
  • funds that were excessively counted on the special accounts of the other specialist (in the amount of overpayment for the IPC) and were spent can be recognized by DFS as used not for their intended purpose.

We estimate the above risks as low, based on the lack of legal grounds. We recommend that you provide registers of payment orders (transfer of funds to VAT accounts) and be prepared to write an application for the cancellation of such an overpayment with the IPC.

Overpayments arose in connection with the payment of VAT (3752 ..., 3753 ..., 3754 ..., 3755 ...) of the sum more than declared in the special VAT returns for the periods from 01.07.2015 to 31.12.2016. Since the funds from the corresponding VAT invoices were returned to the special accounts of the farm enterprises, it is clear that now, when overpaying is canceled, this does not involve the actual return of funds to current accounts.

From the practice of individual enterprises in writing off overpayments from the IPC, there is no reduction in the amount under the CEA VAT formula.

At the same time, we draw attention that in the case of the presence of significant amounts of overpayment in the farm enterprise of the manufacturer of the code of classification of budget revenue 14010160 there is a high probability that the DFS authorities check such a payer.

Tuesday, 25 September 2018


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