What does the tax check when checking cash discipline. Conducting cash discipline according to strict rules

The rules for conducting a check of cash discipline are stated in the legislation of Russia. Let us describe the main features of the fulfillment of their obligations by the tax authorities when exercising control over the audited enterprises in 2019.

If the enterprise uses KKM, it is obliged to comply with the relevant rules and laws that regulate this issue.

This is closely monitored by the authorized bodies, and in case of detection of a violation, they determine the measure of punishment. Special checks are carried out, which will be discussed later.

Basic moments

Consider what is meant by cash discipline and what regulations should be referred to.

Required Definitions

When conducting activities of an economic type, enterprises can apply different kinds calculations. Conducted transactions are cash transactions.

They are registered in accounting in accordance with the rules described in the legislation. The government has also set restrictions on working with cash.

Cash discipline is organized and formulated so that violations testify to intent, not error.

Purpose of the activity

Checking cash discipline is carried out by the tax inspectorate and servicing banking institutions. Cashiers, accountants and company management can work with the cash register.

There is no limit on the number of inspections - the tax authority has the right to check the company's cash desk at least daily ().

Such inspections are not considered field inspections, which means that the rules reflected in the Tax Code cannot be applied to them. Employees of the tax authority consider a year as an average indicator of the frequency of cash discipline audits.

Authorized structures draw up a plan according to which the company will be checked. If you are not included in such a list, then verification is possible only if complaints are submitted.

We list the situations when checking the cash desk can be more often than once a year:

1. If there have been violations in the past.
2. If anyone submits (including not providing checks).
3. If a complaint is filed about receiving informal wages or understatement of the tax base.
4. If the activity of the enterprise is unprofitable.

The company must in without fail comply with cash balance limits. Management annually submits limit calculations to the banking institution. The bank will issue forms for this.

If the company has several current accounts, you can submit settlements to one bank, and submit photocopies to the rest. If the required documentation is not submitted before the new year, the limit will be 0.

It is also worth monitoring the spending of cash, which should be agreed with employees of a banking institution.

You should also adhere to the limit on settlements between legal entities, control the maintenance of cash records, the use of cash registers.

Legal framework

Since the beginning of 2012, the Regulation on the procedure for conducting cash transactions came into force, which was approved.

In February of the same year, the following regulations came into force:

• regarding the verification of the CCP;
• concerning check of cash discipline.

You can also be guided by:

1. etc.

The procedure for checking cash registers by tax authorities

The financial director and the chief accountant must strictly control the execution of operations, taking into account local changes.

Cashiers are not allowed to:

• work without control tapes, glue them at the place of breaks;
• allow unauthorized persons to enter the cash register, approach cash registers(this can only be the director, his deputies, accountant, senior cashier and technical specialists, inspection bodies);
• leave the cash register without warning the authorities, without turning off the cash register, without locking the cash register;
• make adjustments to the programs for the operation of cash terminals;
• keep your funds in the cash register that are not accounted for through the cash register.

Control over the activities of the cashier can be as follows:

If control is carried out by the tax authority, it is worth remembering the following rules.

The terms for checking tax cash discipline are reflected in the Administrative Regulations:

For what period do you need data?

The administrative regulations do not say anything about what period can be covered by the check. It says that a decision on an administrative violation can be issued within 2 months from the date of its fixation.

We can assume that the tax service during the audit will be limited to 2 months. But there are opinions that the audit can also cover longer periods - up to 3 years, which precede the year when the audit is carried out.

What is usually checked?

Examination tax office must be carried out in the presence of an official of the audited organization. At the same time, the norms of the law are observed.

If the correctness of the use of cash registers is checked (settlements with the population, the correctness of the calculation of tax payments):

What tax officials will pay attention to and how they will act:

If KKM is discovered that it has not been registered with the tax service, it is worth checking whether such a device is being operated in secret.

To do this, tax representatives request a passport for such equipment, documentation of its purchase, data from a totalizing meter, and a control tape for such devices.

When checking repair work KKM pay attention:

• whether there is a ;
• whether records are kept in ;
• whether the work performed is recorded in form 30 of the Standard Procedure for the Use of CCP.

If a company has the right to use strict reporting forms, they will be checked by the tax authority. If such documents are not approved by law, then the company does not receive exemption from the use of CCP.

By checking the price list for the services provided, the inspector will determine whether the document is reasonable (when and by whom it was approved, for which industries, departments, enterprises).

He will examine how it is designed (is it clear data, are there necessary signatures, stamps), and is it accessible to customers.

Inspection structures have the right to:

• without obstacles to approach the KKM and other objects of verification;
• request documents related to the use of cash registers and accounting of money;
• check cash at the cash desk and the presence of BSO;
• receive information about the BSO, filling out the form, automatic preparation of documentation, which is equivalent to a cashier's check;
• request an explanation, certificate, data on issues that arise during the audit;
• work together with the internal affairs body;
• get the KKM password, which is more necessary for reporting the fiscal memory readings;
• hold violators accountable.

We list the documents that may be requested by the tax authority:

1. Magazine KM-8.
2. , which is marked by the Federal Tax Service.
3. Magazine KM-4.
4. Cash book KO-4.

What to be afraid of

It is worth considering several nuances. If the inspection bodies find the personal funds of employees, they will consider them as unreceived cash.

Such funds will be credited to the company's profits. Responsible persons will have to explain why there is a surplus in the cash desk (clauses 27, 37 of the Order).

The organization will also be held accountable - a fine will be imposed. Punishment in the form of penalties is also provided for other violations.

Emerging nuances

Let's find out what issues are relevant for firms that use CCP.

If a shortage is found

During the audit of the cash desk, the commission recalculates cash, checks other valuables. Then the balances are checked against the information that is reflected in the cash book.

If a deficiency is revealed, such a fact as the amount itself, the circumstances of its occurrence will be reflected in the act, which will be drawn up at the end of the check.

Video: tax audits

The cashier gives written explanations why the funds at the cash desk did not match the accounting information. The shortage will be recovered from the culprit.

If there is a serious violation of laws, the audit materials are transferred to the investigating body. Proceedings on administrative offenses may also be initiated.

Frequently asked questions about the tax office

What if the organization received money from the buyer on the weekend, because it is not always possible to transfer the proceeds to the bank?

Keeping funds at the cash desk is permissible (and is considered a violation of the law) in such cases:

• on the day of issuing earnings, scholarships, etc.;
• on the day of transfer of social plan funds;
• on weekends, holidays.

It is worth collecting the proceeds no later than 1 business day. What to do if it is not possible to collect funds on the first business day? Issue a means subreport. Upon surrendering the proceeds, the accountable person will return the funds received.

What is the statute of limitations for filing a cash register audit? This period is 2 months. Is there a job penalty? cash register not in the place where it is registered? For example, cash registers are used not in the office, but in the warehouse where the goods are released.

There is no violation in this. Even if cash registers are located in separate divisions that are not on separate balance sheets, but registration of KKM carried out at the place of registration of the company in the Federal Tax Service, a fine is also not assigned.

What are ongoing violations? In the event that the legislative norms of cash discipline are not observed, the company may receive an administrative fine ().

It is appointed within 2 months. If there is a continuing offense - from the moment it is detected (). Continuing violations are listed in paragraph 1 of Art. 4.5 of the Code of Administrative Offenses.

Cash transactions are not a continuing offence. What you can not spend cash from the cash desk:

Penalty system

The most frequent violations:

• there is no primary cash documentation, or it is issued with violations of the rules;
• funds were transferred to the accountable person on the basis of documentation, which confirms the costs, but the advance report is not issued;
• the established limit of cash settlement between companies has not been met;
• errors were identified in the calculations of turnovers and balances in the accounting register, if accounting is carried out manually;
• funds not fully credited.

Fine amount:

If the organization has not transferred taxes due to non-receipt of proceeds to the cash desk, the Federal Tax Service will charge a fine in accordance with or 15.1 of the Code of Administrative Offenses.

But it is worth considering that for one offense a person cannot be held simultaneously to tax and administrative liability.

But the tax authorities do this - the organization is fined under Art. 122 of the Tax Code, and the head and chief accountant - under Art. 15.1 of the Code of Administrative Offenses.

Can they turn up without warning?

Employees of the tax service conduct an audit, warning the company's management. Although it will not be considered a violation if the Federal Tax Service swoops in with an inspection without warning.

The company should pay special attention to cash discipline. Otherwise, there is a risk of running into trouble from employees of the tax authority.

After all, for violations legislative norms will have to bear administrative responsibility. Follow the operations, control the work of the cashier, fulfill your obligations in a timely manner.

Due to the fact that cash transactions are massive, the stage of their verification is very laborious, but the uniformity of operations simplifies verification procedures. Having studied the actual availability of cash and valuables stored at the cash desk, as well as examining the cash economy, the inspector focuses on cash transactions, using, as a rule, a continuous verification method. He draws attention to the procedure for keeping records of cash and other valuables stored in the cash register, compliance with cash discipline, the reliability and legality of cash transactions in national and foreign currencies. First of all, it is necessary to determine whether the organization applies for registration of cash transactions unified forms primary accounting documentation and whether all of its required details are filled out. Analysis of the information contained in the accounting registers on account 50 "Cashier" allows you to establish the volume and nature of cash transactions for the receipt of funds and their expenditure for the period under review.

Then they study:

a) the safety of checks and their stubs in check books;

b) the correctness of determining the balance of money in the cash register, transferring them to the next day according to the cash book and calculating in it the total amounts for income and expenditure for the reporting period;

c) the completeness of the reflection in the cash book and the cashier's reports of all operations with cash, their mutual correspondence;

d) use of cash received from the bank for the intended purpose;

e) the timeliness and completeness of the return to the bank of unused funds;

f) compliance with the limit set by the bank for the balance of cash on hand;

g) the use of cash proceeds for current needs within the established norms.

One of the tasks of the audit is to determine the correctness of the execution of documents on which operations were carried out related to the receipt and issuance of cash.

All cash incoming and outgoing orders (Appendix A), other documents must be filled out clearly, clearly, without blots (no erasures or corrections are allowed in these documents), and the applications that are the basis for receiving or issuing money must be canceled with stamps " Received" or "Paid", dated and signed by the cashier.

The facts of the absence of redemption stamps must be reflected in the working document, as this creates conditions for the reuse of documents.

Pay slips must contain authorization signatures for the payment of money to recipients, indicating the payment period, as well as the signatures of the persons who received the funds, or the mark “Deposited” if the money was not received.

The inspector should make sure that the cash receipts and expenditure orders have separate numbering and were issued in the accounting department at the time of the transaction.

Along with this, the presence and authenticity of signatures of officials and recipients of money on cash warrants and other monetary documents, the legality of cash payments made from the cash desk are being studied.

Facts of signature of consumables are revealed cash documents only one manager or chief accountant, as well as cases of signing by them and issuing blank checks to the cashier for self-filling when receiving money from the bank.

It is necessary to check the reliability of incoming and outgoing cash orders. It is known that unscrupulous cashiers can carry out cash transactions on the basis of false documents or reuse cash warrants.

It should be established who registers issued cash orders in the organization. In accordance with the Instruction on the procedure for conducting cash transactions and cash settlements in Belarusian rubles on the territory of the Republic of Belarus, incoming and outgoing cash orders are filled in and, even before being transferred to the cash desk, the accountant registers in the register of incoming and outgoing cash orders. At the discretion of the head and chief accountant of the organization, there may be two such journals (separately for receipt and expenditure orders) or one general journal.

If registration is by technical means, it is necessary to establish whether the output form “Input sheet of the journal for registering incoming and outgoing cash orders in Belarusian rubles”, compiled for the corresponding day, contains information for accounting for the movement of cash for its intended purpose. The inspector must familiarize himself with the document flow according to cash transactions, with a system of codes, the content of input, intermediate and output information, the procedure for accounting processing of cash documents.

In each checkbook (including unused) sheets are counted and checked for defects in binding and fastening individual sheets. Damaged checks pasted into a checkbook are subjected to research, the sequence of their numbers is studied. This allows you to identify abuses - replacing the spine or damaged check with a new one from another checkbook. Keeping a cash book should be carried out in accordance with the Instruction on the procedure for conducting cash transactions and cash settlements in Belarusian rubles on the territory of the Republic of Belarus.

The organization is allowed to open only one cash book, and it must be numbered, laced and sealed, and the number of sheets in it is certified by the signatures of the head and chief accountant. The regularity of maintaining the cash book and compiling the cashier's report is checked.

It should be borne in mind that when performing transactions on total amount from three or more basic wages, a report must be prepared daily, and less than the specified amount - for a period of three to five days.

Erasures and uncertified corrections in the cash book are prohibited, corrections must be certified by the signatures of the cashier, chief accountant or person replacing him. Entries in the cash book are made by the cashier immediately after receiving or issuing money separately for each incoming or outgoing order.

During the period of issuing cash for wages, for the payment of scholarships, etc. the balance of the cash desk is displayed according to the receipt and expenditure cash orders recorded in the cash book. The line “Including payroll” indicates the amount of the cash balance not paid according to the payroll. At the same time, the amount of cash issued per day according to the payroll for wages, scholarships, etc. an expense cash warrant is not issued and is not reflected in the "Expense" column in the cash book. The payroll for wages must be kept at the cash desk along with the balance of cash and is a document confirming that there is no shortage of cash at the cash desk:

Table 1 - Accounting records for cash transactions of JSC "Belshina" for 02.12.2009.

If the process of maintaining a cash book is computerized, then it is necessary to establish how the safety of cash documents and the protection of software from unauthorized access are ensured, check the availability of the output forms "Cash book insert sheet" and "Cashier's report" (Appendix B, C), which must be compiled simultaneously at the end of the working day, have the same content and all the details provided for in the form of the cash book. The numbering of the sheets of the cash book on these output forms is carried out automatically in ascending order from the beginning of the year.

It is necessary to check whether the total number of sheets of the cash book for the period is printed in the last output form "Cash book insert sheet" for each month (year) and to establish their presence, to find out if the "Cashier's report" form is submitted together with incoming and outgoing cash orders in accounting against receipt in the "Insert sheet of the cash book". Loose sheets of the cash book must be kept by the cashier separately for each month.

At the end of the calendar year (or as needed), they are booked in chronological order, the total number of their sheets is certified by the signatures of the head and chief accountant, and the cash book is sealed.

Checking the calculation in the cash book of the total amounts of turnovers of cash transactions for each page and per day, as well as the correctness of their transfer to another page, is due to common cases of erroneous or deliberate distortion in turnovers and distortions of amounts from one page to another.

Along with this, the compliance of entries in the cash book with the data of the cashier's report and the documents on the basis of which the entries were made is being studied.

Reconciliation of the supporting documents attached to cash orders with the report and the cash book makes it possible to detect possible contradictions between them in terms of income and expenditure transactions.

The inspector establishes the completeness of the reflection in the cash book and cash report of documents on the receipt and expenditure of cash by comparing the receipt and expenditure cash orders and supporting documents attached to them with the data of the cash book and the cashier's report. This allows you to identify the facts of incomplete posting of cash received by checks at the bank institution and from the employees of the organization for the services rendered, as well as the facts of their incomplete write-off as an expense.

After checking the correctness of the cash book, the reality and reliability of the records of the balances of money in the book and in the cashier's reports at the beginning and end of the study period are determined.

Cash balances for certain dates are established using the data of accounting registers for account 50 "Cashier", the General Ledger and balance sheets:

Table 2 - Cash balances of OAO Belshina as of 02.12.2009

In order to make sure that the organization does not practice writing off money at the cash desk on the basis of documents removed from the archive, the inspector pays attention to the color of the paper of cash documents, the uniformity of ink, the uniformity of handwriting, dates - the day, month and year of the documents, and in case of doubt, finds out the reasons for the significant discrepancy between the dates of cash orders in the documents attached to them.

The facts of omissions in the numbering of cash orders or the absence of signatures of officials or individual executors on them are a reason to demand explanations from the cashier and accountant.

After that, a study is made of the documents attached to the cash orders, essentially reflected in their operations. For all suspicious transactions, working records are made in order to check them in more detail during the study of the relevant sections of the financial and economic activities of the organization.

Verification of documents on the merits of the operations reflected in them involves establishing the adequacy of business operations to the current legislation, the rules for performing these operations, approved standards and forecast indicators, as well as determining their economic feasibility.

According to the Instruction on the procedure for conducting cash transactions and settlements in cash in Belarusian rubles on the territory of the Republic of Belarus, the limit on the balance of cash at the cash desk, the procedure and terms for the delivery of cash, the rate of use of proceeds for urgent needs are established by the institutions of the bank in which settlement and foreign currency accounts are opened .

All cash in excess of the limits must be handed over to the bank for crediting to the account:

Table 3 - Accounting records for the collection of cash in excess of the established cash balance limit

The term for the delivery of cash is considered daily, the limit of the cash balance is zero, and cash not deposited with the bank is over the limit for bank customers who have not submitted an application for setting a cash balance limit, the procedure and deadlines for the delivery of proceeds and for issuing a permit for spending cash from the proceeds received by the cashier within the period established by the servicing bank.

Along with this, legal entities have the right to keep cash in their cash desks in excess of the established limit of the cash balance only for wages, scholarships, pensions, allowances, dividends, payments to teaching staff for the purchase methodical literature for a period not exceeding three working days (for agricultural organizations, local authorities and self-government located in countryside, -- no more than five working days), including the day of receipt of money in the servicing bank or the day of the specified payments when used in agreement with the servicing bank for these purposes of revenue.

Upon the expiration of this period (ie on the 4th and 6th working days, respectively), the amounts of cash not used for their intended purpose must be deposited and handed over to the servicing bank.

To verify compliance with the specified procedure, cash book data, accounting registers for account 50 “Cashier”, a collective agreement (it indicates the days of payment of wages), bank permission for a certain cash balance limit are used.

Compliance with the limit is checked by comparing it with the actual cash balances on hand.

The amount of turnover on the cash desk can be clarified by accounting registers, while simultaneously checking the balances at the beginning and end of the month with the data of the cash book or the General Ledger. In case of detection of repeated non-compliance with cash balances at the cash desk, the inspector draws up a cumulative list of violations identified during the audit.

The fact of using funds for other than their intended purpose is established by comparing the data on the stubs of checks in the checkbook with information about their spending in the cashier's reports, the register of incoming and outgoing cash orders, as well as in the accounting registers for the debit and credit of account 50 "Cashier". The results are presented in the corresponding table.

In the course of the study of cash transactions, the completeness and timeliness of posting funds to the cash desk received from the organization's bank accounts are checked. The amounts reflected on the stubs of checks or in receipts for a cash contribution, in cash receipts and debit orders, cashier's reports, bank statements, accounting register for account 50 "Cashier" are compared:

Table 4 - Verification of the correctness and timeliness of the reflection at the cash desk of the receipt of cash by Belshina OJSC

The institution of the bank reflects all operations with cash in statements under a special cipher (code). With this in mind, it is necessary to pay attention to the presence of corrections, erasures, cases of encircling the ciphers of cash transactions with ink, a ballpoint pen or on a printer (copier). At the same time, the check numbers indicated on the stubs and in the statements of the bank institution are verified.

Along with this, you can compare the cash balances on the first day of the month with the balance indicators, as well as the turnover on income and expenditure of account 50 "Cashier" of the General Ledger with data on monthly turnover on the debit and credit of this account. The initial information for determining the monthly turnover is contained on the stubs of checks (debit) and in receipts for cash contributions (credit). The results of checking the compliance of the data of the servicing bank with the entries in the cash book are drawn up in a special table. Separately, the correctness of the use and observance of the procedure for issuing cash under the report is studied. The object of attention of the inspector is the period for which the accountable amounts are issued: sometimes it may indicate illegal advance payments to the employees of the organization: report on future expenses, but the terms for which funds are issued are limited:

No more than 3 working days - for expenses incurred at the location of the organization;

No more than 10 working days - for expenses incurred outside the location of the organization;

Up to 30 working days - in an amount not exceeding the size of one base unit.

Persons who have received cash under the report are obliged, no later than three working days after the expiration of the period for which they were issued, or from the day they return from a business trip (excluding the day of arrival), to submit a report on the amounts spent to the accounting department of the organization and return unused funds to the cash desk .

Verification of documents for a contribution to the cash desk by an accountable person of the amounts of unspent advances is carried out in mutual communication with transactions characterizing the amount of the approved expense report.

By comparing the data of advance reports of accountable persons with the data of incoming cash orders, the cash book and the cashier's report, the correctness and reality of the funds received at the cash desk are checked:

Table 5 - Checking the correctness of the reflection of the receipt of unspent accountable amounts for 02.12.2009. in Russian rubles

The issuance of cash under the report is made subject to a full report on previously issued amounts. The transfer of cash issued under the report to one person to another is prohibited.

To verify these operations, the entries in the accounting register on account 71 “Settlements with accountable persons” are examined, in which analytical and synthetic accounting of settlements with accountable persons is kept:

Table 6 - Accounting records for cash transactions of JSC "Belshina" for 02.12.2009.

The corresponding entries are made in the cash book, and are also reflected in the Journal-order and the Statement on account 50 "Cashier" for December 2012.

When checking cash transactions, control is carried out separately on the expenditure of cash written off to production costs and other accounts without the subsequent submission of reports and supporting documents on the use of funds

Operations on capitalization of proceeds for sold products and services rendered to employees of the organization for cash are subject to a thorough check. It is advisable for the inspector to examine not only cash receipts, but also documents characterizing the release of material assets to the side (waybills, bills, waybills, etc.). At the same time, the turnovers on the debit of account 50 “Cash” and the credit of account 90 “Incomes and expenses on current activities” are compared.

Verification of documents for receipts received at the cash desk for work and services performed begins with an analysis of the calculations attached to the cash orders, characterizing the volume of work or services performed, justification of the price and total cost. These can be cost estimates of work performed, invoices, certificates from accounting, financial and planning departments, and other documents. The inspector draws attention to the legality of the performance of these works or the provision of services, the objectivity of the reasons for performing operations, the correctness of the preparation of estimates and financial calculations or calculations, the reasonableness of prices for materials and services. In necessary cases, the facility is inspected and the control measurement of the work performed or services rendered is carried out. At the same time, it is important to evaluate the quality of work, the quantity and quality of the material used, and the amount of labor costs. Based on the results of the inspection of the object and the control measurement, an appropriate act is drawn up.

In the conditions of using a PC, the data of the machinograms on the receipt of money at the cash desk and on the release of inventory items from the warehouse, as well as their sale to the side, are compared.

Differences in indicators indicate the possibility of the release of raw materials, materials and other valuables without payment or the appropriation of proceeds.

You should check the reports on the movement of inventory and records on the accounts of their accounting and implementation.

Debit entries in the sales account are reconciled with credit entries in the inventory accounts, and credit entries in the sales account are reconciled with debit entries in the cash account. Cash for inventory items sold to the public should be paid to the cash desk of the organization, and the release from the warehouse of materials should be made only if there is an invoice with the stamp of the cash desk “Paid”.

Payroll transactions deserve special attention of the inspector.

Sources for checking the validity of writing off funds to the expense of the cash desk are payroll statements, documents on interim settlements in cases of dismissal or going on vacation, payments of unscheduled advances, etc. When examining payroll statements, the inspector should verify the presence and reliability of signatures in receiving money, the correctness of calculating the totals of the amounts of issued and deposited wages. The authenticity of signatures can be established by comparing them with signatures on similar documents, or in the statements of previous months, or on documents from the personnel department. In some cases, a survey of recipients of funds is carried out.

In the course of checking cash transactions related to the payment of wages, it is advisable to make working notes in order to return to the issues that have arisen and thoroughly study them when checking the organization of labor and wages.

Reconciliation of settlement and payment documents with the data of the personnel department shows the validity of including individual employees in the statements. In a selective way, according to the time sheets, persons working in organizations and included in the payroll on the basis of orders for admission to work and dismissal are established. The payroll also checks the totals in the column "To be handed over".

Errors and abuses can be allowed by increasing the total without changing the amounts reflected line by line, and with their change, i.e. when the amount is artificially increased to one of the recipients of funds.

When checking documents for issuing cash to persons who are not on the payroll, it is important to study the possible marks in the cash receipt, the name and other details of the identity document of the recipient (number, by whom and when issued). If necessary, the inspector takes measures to establish the place of residence of the recipients of funds and finds out any questions they have.

In the process of studying cash transactions for the payment of wages temporary workers and part-time workers are drawn attention to the reliability of documents confirming the amount of time worked, the correctness of registration labor agreements, the reality of the fact of the work, the validity of the applied prices. The objective possibility of performing work by this person is specified, taking into account his qualifications and location at the time when these works were carried out. The inspector must establish whether full-time employees do not receive money under cash receipts for performing one-time work that is directly included in their job responsibilities.

Particular attention should be paid to operations on deposited amounts of wages and other payables.

You should check for the presence of a stamp or entry "Deposited" in the payroll against the names of persons who did not receive wages, make sure that the register of deposited amounts is compiled and all amounts are written to whom. The correctness of the book of deposited wages and the timeliness of the reflection of the corresponding amounts in it are also checked.

In order to identify cases of repeated payments of wages and payments of deposit debts to nominees, it is advisable to conduct a cross-check: compare the payrolls, according to which the amount was deposited, with the ledger of deposit amounts, cash disbursement orders for the issuance of deposit debt, as well as with debit entries in personal accounts employees of the audited organization.

Similar actions are taken if receipts confirming the transfer of deposited debts by postal orders are attached to the cash order, or there are suspicions that the postal order was issued to a front person, and the transferred amount is reflected in the book of deposit amounts as debt repayment. In such cases, in order to verify the authenticity of the amount transferred to the recipient, written requests are made or a visit is organized to the persons who had a deposit debt, or a counter check is carried out in post offices by mail order stubs. Special attention the inspector must pay attention to the correspondence of accounts with the current regulations and rules for maintaining accounting. This is carried out on the basis of data from the cashier's reports and supporting documents attached to them, as well as entries in accounting registers in order to identify business transactions with incorrect correspondence of accounts that lead to distortion of accounting and reporting or write-off of stolen amounts.

At the end of the check of cash transactions, it is necessary to study the correspondence of accounts for each cash transaction, the completeness of the reflection of the amounts on the corresponding accounts, the correctness of calculating the totals line by line and in each column of the relevant accounting registers for account 50 “Cashier, the relationship with the corresponding accounts reflected in other registers.

Each total amount of the accounting register is compared with the totals for the receipt and expenditure of money of the corresponding cash report, then the correctness of posting operations from the cashier's report to accounting registers for corresponding accounts is checked. In case of detection of violations of cash and settlement and payment discipline, the inspector draws up a cumulative statement.

Typical accounting errors and omissions encountered in the process of checking cash transactions:

Settlements with the population are carried out without the use of cash registers;

There is no agreement with the cashier on a full individual or collective (team) liability;

Documents that are the basis for receiving or issuing money are not canceled with the stamps "Received" or "Paid" with the date indicated;

Cash balance limit exceeded;

The maximum allowable amount of cash settlements between legal entities has been exceeded;

There are no documents confirming the fact of cash register inventory;

The movement of cash is reflected in the cash book for several days on one sheet;

Incoming (expenditure) cash orders do not indicate the grounds for receiving cash;

There is no journal of registration of incoming and outgoing cash orders;

The cash book is not stitched, its sheets are not numbered;

Cash funds are issued from the cash desk against the report in the absence of a complete report of a specific accountable person on a previously issued advance;

The document proving the identity of the recipient when issuing cash from the cash desk is not specified;

There are no signatures of persons who received cash from the cash desk;

There are no powers of attorney to receive funds from the cash desk;

Peculiarities of checking the cash register and cash transactions in the conditions of an automated form of accounting and ways to improve them

The development and rationalization of accounting are characterized by the improvement of the applied forms of accounting. The need to move from one form of accounting to others, more advanced, is determined by the development of the enterprise. The use of personal computers in accounting work makes it possible to automate workplace accountant, which increases the productivity of accounting workers, ensures the efficiency of obtaining data. In addition, there is an opportunity to improve the conduct of economic analysis. This creates an information base for making effective management decisions.

The use of personal computers allows you to automate the processing of credentials from their input to the formation of output forms. The user enters the data of primary documents, which are then using special programs grouped and summarized directly on the computer. As a result, it is possible to obtain various information, equivalent in content to the registers of synthetic and analytical accounting, and use it repeatedly.

With automated accounting technological process is divided into four stages:

Collection, registration and transfer of primary data for processing on a computer;

Data entry of primary documents into the computer;

During the reporting period, the formation of operational accounting registers in the form of machinograms or displaying the required information on the monitor screen;

Obtaining results for the reporting period in the form of registers of synthetic and analytical accounting, certificates of accounts, analytical tables, balance sheets and other forms of reporting, depending on the capabilities of a particular software package.

The output data can be presented in the form of various registers in the form of order journals, statements, etc., and differ depending on the specific program for automated information processing (“1C: Accounting”, “Galaktika”, “Vetraz”, etc.). The methods for entering primary data are also different. At the same time, all of them are united by the fact that they function on the basis of the interaction of the elements of the accounting method: documentation, inventory, accounts, double entry on accounts, assessment and costing, balance sheet, reporting. JSC "Belshina" uses journal-order and automated form accounting.

The purpose of the audit of cash transactions is to establish the compliance of the methodology used at the enterprise for accounting and taxation of operations on the movement of cash with the current regulatory documents Russian Federation.

Cash transactions are checked by a continuous method, since it is in this area of ​​\u200b\u200baccounting that violations and abuses are possible.

The sources of verification of cash transactions are:

· regulations

Accounting statements (balance sheet and cash flow statement);

Order on the accounting policy of the enterprise;

registers of accounting for cash transactions (statement No. 1 and journal-order No. 1);

· primary documents for accounting of cash transactions (incoming and outgoing cash orders, cash book, accounting books for incoming and outgoing cash orders, payrolls).

The audit of cash transactions is organized in the following sequence:

1. inventory of cash and study of the conditions of storage of funds;

2. verification of the correctness of the documentation of transactions;

3. checking the completeness and timeliness of posting funds;

4. checking the correctness of debiting money as an expense;

5. verification of compliance with cash discipline;

6. verification of the correctness of the reflection of operations on the accounts of accounting;

7. registration of the results of the check.

Arriving at the place of verification, the auditor immediately conducts an inventory of the funds stored in the cash register. It is carried out in the presence of the cashier and the chief accountant of the enterprise.

If there are several cash desks, the auditor seals them up so that it is impossible to cover the shortage of money in one cash desk at the expense of others, to change the balance of money displayed in the cash book. The cashier provides the last cash report and transaction documents for verification last day, and also gives a receipt that all receipts and expenditure cash documents of the commission have been presented in full and by the time of the inventory at the cash desk unreceived or there is no money not written off as an expense.

The results of the inventory are drawn up in an act signed by the cashier and the chief accountant. The act is a written audit evidence, and its data are necessary for the auditor for further verification.

As a result of the inventory of cash on hand, surpluses or shortages may be detected. The accountant must reflect the results in accounting within 10 days. So the surplus money falls and is attributed to financial results(D 50 "Cashier" K 91 "Other income and expenses"). Deficiencies are attributed to the cashier (if there is an explanatory note), that is, entries are made: D 94 “Shortages and losses from damage to valuables” K 50 - if a shortage is detected, D 73/2 “Calculations for compensation material damage» To 94 - when attributing the shortage to the cashier.

Simultaneously with the inventory, an inspection of the conditions for storing funds is carried out. In its course, the auditor should find out:

· whether the safety of money is ensured upon delivery from the bank and during the issuance of wages;

Whether there is a safe or a fireproof cabinet for storing money at the cash desk;

Whether the rules for storing keys to a safe or a fireproof cabinet are followed. Thus, in the Procedure for Conducting Cash Operations, it is established that the keys to the seal safes are kept by cashiers, who are prohibited from transferring to unauthorized persons or making unrecorded duplicates. Accounted duplicates of keys are stored in packages sealed by the cashier, caskets at the heads of enterprises. At least once a quarter, they are checked by a commission appointed by the head of the enterprise, its results are recorded in the act;

Whether the established limit of money in the cash register is observed;

Is there an agreement on the full liability of the cashier.

Enterprises can have cash in their cash desks within the limits set by banks, in agreement with the management of the enterprise. The cash balance limit for enterprises from January 1, 1998 is set in accordance with the Regulation of the Central Bank of the Russian Federation dated January 5, 1998 No. 14-P “On the rules for organizing cash circulation in the territory of the Russian Federation”.

Enterprises are obliged to hand over to the bank all cash in excess of the established limits on the balance of cash on hand in the manner and terms agreed with the servicing bank. For an enterprise that has not submitted a calculation for setting a cash balance limit to any of the bank's servicing institutions, the cash balance limit is considered zero, and the unpaid cash is considered to be over the limit.

A certificate from the bank on the establishment of the cash limit of the enterprise must be submitted for the audit. Exceeding the established limits at the cash desk is allowed only within 3 working days during the period of payment of wages, bonuses, temporary disability benefits to employees of the enterprise. In the regions of the Far North, this period has been extended to 5 days

Cash can come to the cash desk from banks, from employees of the enterprise and others.

The auditor checks the completeness and timeliness of the posting of money received for each check from the bank by reconciling identical amounts recorded in the check stubs and bank statements (according to the code corresponding to the receipt of cash). Checkbooks, stubs of used checks, as well as unused checks must be kept by the chief accountant in conditions that exclude the possibility of their loss. Spoiled checks are canceled with the “cancelled” stamp and kept glued to the check stubs.

The company determines the use of funds and their intended use at its own discretion. Account holders on the back of cash receipts indicate the intended purpose of the funds received. According to the current legislation, no liability measures are provided for enterprises that have allowed the misuse of money received from the bank. but commercial banks can check the intended use of the funds received and, if necessary, present appropriate requirements to them.

The auditor must carefully check the completeness of posting proceeds from the sale of products, works, services. In this case, it is necessary to check the entries in the cash book, incoming cash orders with reports, invoices and invoices (invoices) for the sale of products, works, services.

The rules for making settlements in Russia and limiting cash settlements are established by the Central Bank of the Russian Federation. Currently, the maximum cash settlement for one transaction between legal entities is set at 60,000 rubles.

During the audit, the auditor identifies cases of excess cash settlement between enterprises and promptly informs the manager about possible sanctions.

The audit shows that largest number violations in the expenditure of funds from the cash desk is associated with cash payments to employees and accountable amounts.

Wages, temporary disability benefits, bonuses are issued from the cash desk according to payroll or payroll, signed by the head and chief accountant. All disbursements of money must contain the signature of the recipient of the money. It is possible to issue money by proxy, in this case the cashier makes an entry “by proxy”, and the power of attorney itself attaches to the statement.

When checking the correctness of the payment of money according to payrolls, the auditor should establish whether all the persons included in them are employees of the enterprise.

To prevent such violations, the personnel department must endorse payrolls before paying money on them.

When checking the spending of money, the auditor checks the operations for the issuance of money report.

Accountable persons are employees of the enterprise who receive cash from cash desks for business and travel expenses. In accounting for settlements with accountable persons, account 71 “Settlements with accountable persons” is used.

The Procedure for conducting cash transactions states that accountable persons are required, within 3 working days, after making the last expense or upon returning from a business trip, to submit to the accounting department a report on the amounts spent and make a final settlement on them.

The auditor should carry out procedures to find out whether the enterprise repays the accountable amounts in a timely manner. If the audit reveals that the accountable amounts are accrued to the employees who received them for longer than the established period, then the auditor needs to obtain written explanations from the relevant officials. You should also warn both accounting staff and the accountable person about the need to include outstanding accountable amount in the taxable turnover on personal income tax.

All cases of violations of expenditure cash transactions must be recorded by the auditor in working documentation. They calculate the total, which is commensurate with the credit turnover on account 50 "Cashier" to determine the level of significance of errors.

In accordance with the Law of the Russian Federation of June 18, 1993 No. 5215-1 “On the use of cash registers when making settlements with the population”, when conducting trade operations or providing services on the territory of the Russian Federation, all enterprises (including individuals engaged in entrepreneurial activities without formation of a legal entity) are required to use cash registers (KKM). Only some enterprises, due to the specifics of their activities or location, can carry out settlements with the population without the use of cash registers.

To check the completeness of posting revenue through cash registers, the auditor checks the identity of the amount according to the cash tape, book cashier-operator and cash book. At the same time, he checks whether the amounts received have been recorded in the sales accounts.

Control over compliance with the rules for the use of cash registers and the completeness of accounting for revenue is carried out by the tax authorities. For violation of the procedure for conducting cash transactions, an enterprise can be fined in the amount of 400 to 500 minimum wages.

The auditor should warn the management of the enterprise about possible negative consequences, in connection with the violation of the procedure for the use of cash registers.

October 11

Document's name:

Letter of the Federal Tax Service of Russia dated September 12, 2012 N AS-4-2 / ​​15195

A comment:

Since the current year, a new Regulation on the procedure for conducting cash transactions with banknotes and coins of the Bank of Russia on the territory of the Russian Federation, approved by the Bank of Russia on October 12, 2011 N 373-P (hereinafter - the Regulation), has been in force. Recall that this procedure applies to both legal entities and individual entrepreneurs. Explanations regarding compliance with the Regulations by entrepreneurs, the Federal Tax Service of Russia gave earlier in the Letter of December 21, 2011 N AS-4-2 / [email protected](for details, see the release of the review dated 01/12/2012). In the commented Letter, the issues of the duration and frequency of checking cash discipline, as well as maintaining the cash book by separate divisions, are considered.

Frequency and timing of checks of cash discipline

Control and supervision over the completeness of accounting for cash receipts in organizations and individual entrepreneurs is carried out by tax inspectorates (clause 1, article 7 federal law dated May 22, 2003 N 54-FZ). The duration of such an audit may not exceed 20 working days from the date of presentation to the organization (entrepreneur) of the instruction of the head of the tax authority (his deputy) to conduct an audit (clauses 19, 23 of the Administrative Regulations for Enforcement by the Federal Tax Service state function on the implementation of control and supervision over the completeness of accounting for cash receipts in organizations and individual entrepreneurs, approved by Order of the Ministry of Finance of Russia dated October 17, 2011 N 133n (hereinafter referred to as the Regulations)).

The Federal Tax Service of Russia indicated that the check of cash discipline does not apply to field checks, therefore, the provisions of tax legislation in this case do not apply.

Thus, the current regulatory legal acts do not limit the frequency of audits of the completeness of revenue accounting. Accordingly, the inspectorate may conduct such audits several times a year.

It should be noted that the tax authorities, in the course of checking cash discipline, have the right to request an administrative document on the established cash balance limit, a cash book, advance reports and other documents (clause 29 of the Regulations). If, as part of a tax audit, the documents requested by the inspectorate are not submitted on time, the taxpayer may be held liable under Art. 126 of the Tax Code of the Russian Federation. However, since, as the Federal Tax Service of Russia pointed out, the norms of the Tax Code of the Russian Federation are not applied when checking cash discipline, then bring to responsibility under Art. 126 of the Tax Code of the Russian Federation for failure to submit any documents during such an inspection, the inspection is not entitled.

In addition, it follows from the commented Letter that the legislation does not define the period that may be covered by the check of cash discipline. For tax audits, such a period cannot exceed three years preceding the year in which the decision to conduct an audit was made (clause 4, article 89 of the Tax Code of the Russian Federation), but, as the Federal Tax Service of Russia explained, this requirement does not apply to verification of the completeness of revenue accounting. This means that inspectors can check any period. However, it is not always possible to hold accountable for violations identified during such an audit due to the following.

As the Federal Tax Service of Russia recalled, violation of the procedure for working with cash and the procedure for conducting cash transactions is an administrative offense. So, according to part 1 of Art. 15.1 of the Code of Administrative Offenses of the Russian Federation, a fine in the amount of 40,000 to 50,000 rubles. for legal entities and from 4,000 to 5,000 rubles. for entrepreneurs (by virtue of Article 2.4 of the Code of Administrative Offenses of the Russian Federation they are equated with officials) is established, in particular, for the accumulation of cash in excess of the established limits. In Art. 4.5 of the Code of Administrative Offenses of the Russian Federation defines the statute of limitations for bringing to responsibility for committing administrative offense. Failure to comply with cash discipline does not apply to violations of the legislation on taxes and fees, therefore, the statute of limitations for bringing to administrative responsibility under Art. 15.1 of the Code of Administrative Offenses of the Russian Federation is two months from the date of the offense. Accordingly, if the inspectors, when checking the completeness of accounting for cash receipts, establish an excess of the balance limit, which was allowed more than two months ago, then by virtue of clause 6 of Art. 24.5 of the Code of Administrative Offenses of the Russian Federation for such offenses, a fine under Art. 15.1 of the Code of Administrative Offenses of the Russian Federation cannot be imposed on an organization or an entrepreneur. Similar clarifications are contained in the Letter of the Federal Tax Service of Russia for Moscow dated April 23, 2008 N 09-10 / [email protected]

Keeping a cash book by separate divisions of the organization

The Federal Tax Service of Russia, with reference to the Letter of the Bank of Russia dated May 4, 2012 N 29-1-1-6 / 3255, indicated that the requirement contained in the Regulation to maintain a cash book 0310004 must be observed by each separate division of the organization conducting cash transactions. In this case, it does not matter whether a bank account is opened for the division to perform these operations.

Recall that when receiving or issuing cash, the cashier makes entries in the cash book 0310004 for each incoming cash order 0310001 or outgoing cash order 0310002 (clause 5.2 of the Regulations). In accordance with clause 5.6 of the Regulations, in order to control compliance with the cash balance limit, the separate division, after withdrawing the amount of the cash balance at the end of the working day in the cash book, transfers the cash book sheet for this business day to the legal entity no later than the next business day. Such sheets are selected and brochured by the organization for each separate division (clause 2.5 of the Regulations).

It should be noted that organizations (entrepreneurs) determine the cash balance limit on their own in accordance with the formula given in the appendix to the Regulation. If separate subdivisions do not have their own current accounts, then the organization determines such a limit, taking into account the cash held in the subdivisions (clause 1.3 of the Regulations). Separate divisions those who have bank accounts, for performing cash transactions, separately set the amount of the maximum balance of money on hand (clauses 1.2, 1.3 of the Regulations).

The review was prepared by Consultant Plus specialists and provided by ConsultantPlus Sverdlovsk Region, the information center of the ConsultantPlus Network in Yekaterinburg and the Sverdlovsk Region

Since January 1, 2012, the Regulations on the procedure for conducting cash transactions with banknotes and coins of the Bank of Russia on the territory of the Russian Federation, approved by the Central Bank of the Russian Federation on October 12, 2011 No. 373-P, are in force. Now the functions of checking compliance with cash discipline by organizations and individual entrepreneurs have been transferred to the tax authorities. Immediately, two new administrative regulations of the Federal Tax Service came into force in February 2012: on checking cash registers (CCP) and on checking cash discipline.

If the first administrative regulation is of interest to those who use cash registers, then the second affects the interests of all taxpayers who carry out cash cash settlements or payments using payment cards. Let us consider in detail how the tax authorities will conduct cash discipline checks.

New administrative regulations of the Federal Tax Service

According to Art. 7 of the Federal Law of May 22, 2003 No. 54-FZ "On the use of cash registers in the implementation of cash settlements and (or) settlements using payment cards" (hereinafter - Federal Law No.54-FZ) control over the application of CCPs is carried out by the tax authorities. On February 5, 2012, the Administrative Regulations for the Federal Tax Service to perform the state function of exercising control and supervision over compliance with the requirements for cash registers, the procedure and conditions for its registration and use, approved 132n. The subject of state control in this case is the observance by individual entrepreneurs and organizations, with the exception of credit, of the requirements for cash register equipment, the procedure and conditions for its registration and application. Those taxpayers who work with cash registers are already familiar with the tax inspection departments in which they registered their cash registers. This type audits have been carried out for a long time and regularly, so let's move on to a new form for the tax authorities - checking the completeness of revenue accounting.

On February 19, 2012, the Administrative Regulations for the implementation by the Federal Tax Service of the state function of exercising control and supervision over the completeness of accounting for cash proceeds in organizations and individual entrepreneurs (hereinafter - Administrative regulation), approved Order of the Ministry of Finance of the Russian Federation dated October 17, 2011 No.133n.

Tax authorities have the right to exercise control over the completeness of accounting for revenue in organizations and individual entrepreneurs on the basis of paragraph 1 of Art. 7 Federal Law No.54-FZ And paragraph 1 of Art. 7 of the Law of the Russian Federation of March 21, 1991 No.943-1 "On the tax authorities of the Russian Federation".

Recall that until 2012, the issues of checking cash discipline, the cash balance limit were the prerogative of the bank in which the taxpayer's settlement account was opened. Such checks were carried out regularly - once every two years, without causing any special worries among the bank's customers.

Checking cash discipline: how and what will be checked?

The subject of state control is the establishment of the fact of the completeness of accounting for cash receipts in organizations and individual entrepreneurs.

Note:

For the purposes of this audit, the objects being inspected (persons in respect of which control (supervision) measures are being taken) include organizations (except for credit ones) and individual entrepreneurs that carry out cash settlements and (or) payments using payment cards or their authorized representatives.

The terms and sequence of administrative procedures in the exercise of control and supervision over the completeness of accounting for cash receipts in organizations and individual entrepreneurs, as well as the procedure for interaction of territorial inspections of the Federal Tax Service with organizations and individual entrepreneurs in the performance of a state function, are established administrative regulations.

Thus, now the check of cash discipline will be carried out by tax inspections, in which taxpayers - organizations and individual entrepreneurs - are registered.

Regulatory framework for the implementation of the state function

The execution of the state function in question is regulated by:

Code of Administrative Offenses of the Russian Federation;

Law of the Russian Federation of March 21, 1991 No. 943-1 "On the tax authorities of the Russian Federation";

Federal Law No. 54-FZ;

Federal Law No. 103-FZ dated 03.06.2009 “On the activities of accepting payments from individuals carried out by payment agents”;

Decree of the Government of the Russian Federation of September 30, 2004 No. 506 “On approval of the Regulations on the Federal Tax Service”;

Decree of the Government of the Russian Federation of July 23, 2007 No. 470 “On approval of the Regulations on the registration and use of cash registers used by organizations and individual entrepreneurs”;

Decree of the Government of the Russian Federation of 06.05.2008 No. 359 “On the procedure for cash settlements and (or) settlements using payment cards without the use of cash registers”;

Order of the Federal Tax Service of the Russian Federation dated 02.08. 2005 No. SAE-3-06/ [email protected]"On approval of the List of officials of the tax authorities of the Russian Federation authorized to draw up protocols on administrative offenses";

Order of the Ministry of Finance of the Russian Federation dated 09.08.2005 No. 101n “On Approval of the Regulations on the Territorial Bodies of the Federal Tax Service”;

Order of the Ministry of Industry and Energy of the Russian Federation dated 05.09.2007 No. 351 “On Approval of the Model Seal of Cash Registers”;

Order of the Ministry of Industry and Energy of the Russian Federation dated 05.09.2007 No. 352 “On Approval of the Sample Identification Mark for Cash Registers”;

Order of the Ministry of Finance of the Russian Federation dated December 18, 2007 No. 135n “On Approval of the Sample of the “Service Maintenance” Sign;

Order of the Ministry of Finance of the Russian Federation of December 18, 2007 No. 136n “On Approval of the State Register Sign Model”;

Order of the Federal Tax Service of the Russian Federation dated April 9, 2008 No. MM-3-2 / [email protected]"On approval of application forms for registration of cash registers, accounting books for cash registers and registration cards for cash registers."

Rights and obligations of officials of tax authorities

Inspectors have the right to:

Have unhindered access to the cash register equipment of the checked object, stored used control tapes, fiscal memory drives and software and hardware that provide uncorrectable registration and non-volatile long-term storage of information in the cash register equipment, and automated systems that generate strict reporting forms (SFR) and documents on these forms, equated to cash receipts;

Request for verification documentation from the audited object related to the use of cash registers and accounting of funds;

Carry out a check of the cash desk and the actual availability of BSO;

Receive information about BSOs generated by automated systems, filling out forms and issuing documents equated to cash receipts by an automated system (information from automated systems about issued documents);

Receive the necessary explanations, references and information on issues that arise during the performance of a state function;

Receive cash register passwords necessary for reporting readings of fiscal memory and control tape;

Interact with the internal affairs bodies of the Russian Federation;

Bring objects of control to administrative responsibility in the cases and in the manner established by the Code of Administrative Offenses of the Russian Federation.

But the duty of the representatives of the Federal Tax Service is only one - to comply with the provisions administrative regulations.

Rights and obligations of the persons being inspected

The verified persons have the following rights:

To be directly present during the audit, to give explanations on issues related to the subject of the audit;

Receive from the inspectors information that relates to the subject of the audit and the provision of which is provided administrative regulations;

Get acquainted with the results of the audit and indicate in the audit report that they have read the results of the audit, agree or disagree with them, as well as actions (inaction) of tax authorities;

Appeal against the actions (inaction) of the inspectors, which entailed a violation of the rights of the object being checked during the inspection, in a pre-trial (out-of-court) and (or) judicial procedure in accordance with the legislation of the Russian Federation.

The examinees are required to:

Provide controllers with unhindered access to cash registers and documentation related to the acquisition and registration, commissioning and use of cash registers, and automated systems that generate BSO and documents on these forms, equated to cash receipts;

Provide information on the BSO generated by automated systems, filling out forms and issuing documents equated to cash receipts by an automated system (information from automated systems on issued documents);

Provide the necessary explanations, references and information on issues arising during the audit;

Provide information to the inspectorate upon request in the manner prescribed by federal laws.

Check procedure

The scheme for checking the completeness of accounting for cash proceeds is as follows:

Presentation of an order to the inspected object to perform a state function;

Review by reviewers required documents;

Checking the completeness of accounting for cash receipts;

Formulation of test results.

It should be noted that the result of the execution of this state function is the drawing up of an act of checking the completeness of accounting for cash receipts, and in the event of an offense being detected, the initiation of proceedings on an administrative offense in accordance with the Code of Administrative Offenses of the Russian Federation.

Start of verification. The basis for starting the audit is the decision of the head (deputy head) of the tax inspectorate to conduct an audit of the completeness of accounting for cash receipts from the audited object. The inspectors present to the checked object an order and service certificates. This fact is recorded by the signature of the verified object, indicating the position and date of presentation in the order. In case of absence or avoidance of the checked object from familiarization and fixing the fact of presentation of the order, the inspectors make a note in the order.

Review of documents. Now the immediate consideration of documents related to the acquisition and registration, commissioning and use of CCPs begins.

In the event that the inspected facility provides services to the public and cash settlements and (or) settlements are made using payment cards without the use of cash registers, subject to the issuance of a document issued on the BSO, equated to a cash receipt, documents related to the manufacture, acceptance, accounting , storage, issuance, inventory and destruction of BSO.

If the formation of a document issued on the BSO, equated to a cash receipt, is carried out using an automated system, the inspectors are provided with information from automated systems about issued documents.

If the audited entity, which is a UTII payer, when implementing types entrepreneurial activity established paragraph 2 of Art. 346.26 of the Tax Code of the Russian Federation, performs cash settlements and (or) settlements using payment cards without the use of cash register equipment, subject to the issuance at the request of the buyer (client) of a document (sales receipt, receipt or other document confirming the receipt of funds for the relevant product (work, service)), controllers are provided with documents related to the issuance of sales receipts, receipts or other documents confirming the receipt of funds for the relevant goods (work, service).

What other documents may be requested by inspectors? As stated in administrative regulations, depending from the period under review and the specifics of cash settlements the following documents are considered:

Journal of the cashier-operator;

Act on the return of money to buyers (clients) on unused cash receipts;

Journal of registration of indications of summing cash and control counters of cash registers, working without a cashier-operator;

Printouts of reports from the fiscal memory of cash registers and used fiscal memory drives;

Control tapes of cash registers on paper and (or) printouts of the control tape made on electronic media;

Incoming and outgoing cash orders;

Journal of registration of incoming and outgoing cash documents;

Expense reports;

Cash book;

Help-report of the cashier-operator;

Information about the readings of KKT meters and the organization's revenue;

BSO, copies of BSO, document backs;

Information from the automated system about issued documents;

BSO acceptance certificate;

BSO accounting book;

Act on the write-off of the BSO;

Book of accounting for income and expenses and business operations of an individual entrepreneur;

Book of accounting for income and expenses of organizations and individual entrepreneurs using the simplified taxation system;

The book of accounting for the income of individual entrepreneurs applying the USNO on the basis of a patent;

Book of accounting for income and expenses of individual entrepreneurs applying the Unified Agricultural Tax;

Administrative document on the established limit of the cash balance;

Other primary accounting documents and accounting registers that are necessary for inspectors to perform the state function.

Looking at the list of documents that inspectors may request, I would like to note that it is extensive and open. This means that representatives of the Federal Tax Service can also check other documents that are not included in this list, but which are of interest to the inspectors. Of course, in administrative regulations it is said that inspectors are not entitled to demand documents and information that are not related to the subject of verification, but the inspectors themselves will also draw a line between what belongs to the subject of verification and what is not.

If we recall checks of cash discipline by banks, then documents were presented for the last quarter and only those that were directly related to cash transactions: cash book, cashier's reports, cash balance limit, advance reports. Banks did not check cash registers at all, this was originally the prerogative of the tax authorities, and banks did not study accounting registers either.

IN administrative regulations nothing is said about the form in which documents will be requested for verification. If we draw a parallel with tax audits, there is a specific procedure for requesting documents: issuing a requirement for the submission of documents, the procedure for their submission, deadlines and liability for non-submission. It should be noted that these audits are carried out by tax authorities not within the framework of tax legislation, and the procedure for their conduct is established administrative regulations.

In the case under consideration, the inspected person is presented only with an instruction to conduct an inspection. It can be assumed that the inspectors will request documents in oral, but then how will they confirm the very fact of the request? At the same time, in administrative regulations says: the fact of receipt or non-receipt of the requested documents is recorded in the inspection report.

Note:

The documents required for verification are submitted by the verified object in the form of originals or duly certified copies. Inspectors are not entitled to require notarization of copies of submitted documents.

Checking the completeness of accounting for cash receipts. After the completion of the consideration of the necessary documents, the administrative procedure begins directly to verify the completeness of accounting for cash proceeds. During the audit, financial and business transactions performed by the audited object during the audited period are studied. Control actions for the actual study are carried out by inspection, inventory, observation, recalculation, examination. They can be carried out both in a continuous and selective way.

At this stage, the inspectors receive from the inspected object the necessary written explanations, references and information on issues arising during the inspection, documents and their certified copies necessary for carrying out control actions. If necessary, in cases requiring the use of scientific, technical or other special knowledge, experts (expert organizations) are involved in the verification.

At the same time, it is mandatory to check the cash in the cash drawer of the CCP by withdrawing the balance (recalculation) of cash, taking into account the funds issued to the cashier before the start of the work shift as a bargaining chip, about which an act on checking cash is drawn up, located in the CCP cash drawer, in two copies.

Before starting this stage, the cashier gives a receipt on the absence or presence of personal money in the cash drawer of the CCP, submission of all receipts, cash receipt orders on the handed over proceeds, certificates-reports of the cashier-operator, information on the readings of the CCP counters and proceeds, acts on the return of money to customers (clients) on unused (returned) cash receipts for the day of verification. The receipt is drawn up in the act of checking the cash in the cash drawer of the CCP.

For each fact of discrepancy, the person being checked gives written explanations.

Before removing fiscal reports, shift reports of CCPs, the serial numbers of these machines, as well as their registration numbers and TIN, are checked against the data entered in the CCP registration card. On the control tape, the presence of all serial numbers cashier's checks, the numbers and amounts of cashier's checks printed on the control tape are compared with the numbers and amounts of existing cashier's checks (if any).

According to the fiscal report of the CCP and the journal of the cashier-operator, acts on the return of funds to buyers (clients) on unused cash receipts, cash receipts, the number of return facts, as well as the amount of money returned to buyers (clients) on unused cash receipts are checked.

In case of discrepancies between the actual and accounting data, the reasons are clarified, detailed explanations are taken and conclusions are drawn on the completeness of accounting for the cash proceeds of the audited object, as well as on the application (non-application) of CCP, BSO and other possible reasons current shortage (the presence of surpluses).

When making cash payments and (or) settlements using payment cards without the use of cash registers, in the case of the provision of services to the population, subject to the issuance of the BSO, the actual availability of the BSO is checked, as a result of which the corresponding act is drawn up in two copies. Verification of the actual availability of forms of documents of strict accountability is carried out by their types, taking into account the initial and ending numbers of certain forms of documents.

When checking at inspected objects that use BSO, the number of forms used for the period under review is determined based on the ledger of document forms, BSO acceptance certificates and BSO inventory certificates for comparison with the actual number of copies of used BSO (document stubs) stored at the audited object. The amount of cash proceeds reflected in the accounting of the audited object is compared with the amounts reflected in the copies of the used BSOs (document stubs) stored with the audited object.

If the inspected object, which is a UTII payer, when carrying out the types of entrepreneurial activities established paragraph 2 of Art. 346.26 of the Tax Code of the Russian Federation, makes cash settlements and (or) settlements using payment cards without the use of cash register equipment, subject to the issuance, at the request of the buyer (client), of a document (sales receipt, receipt or other document confirming the receipt of funds for the relevant product (work, service)), the availability of sales receipts, receipts or other documents confirming the receipt of funds for the relevant goods (work, service) is checked.

The result of this administrative procedure is the establishment (identification, fixation) of the facts of incomplete or complete accounting of cash proceeds, which are recorded in the audit report.

Registration of results of execution of the state function. Based on the results of the audit, an act is drawn up in two copies, which is signed by the tax authorities and the audited object.

The inspection report must be drawn up on paper, drawn up in Russian and have continuous page numbering. In the act of verification, blots, erasures and other corrections are not allowed, with the exception of corrections specified and certified by the signatures of representatives of both parties.

The act of inspection must indicate the documented facts of violations identified during the inspection, or a record of the absence of such. In the description of violations, the provisions of regulatory legal acts that were violated should be indicated. Also, an entry is made in the act on written explanations (comments, objections) received from the inspected object on the facts of violations (if any).

If the object being checked evades signing the act, this fact is reflected in the verification act, which is sent by mail by registered mail at the location or place of residence of the inspected object.

In the event that facts of violations of the legislation of the Russian Federation are revealed, representatives of the tax authorities initiate and carry out proceedings on an administrative offense in the manner established by the Code of Administrative Offenses of the Russian Federation.

Timing of the audit

Administrative regulation establishes maximum terms for each administrative procedure in question. We present them in the table.

Pre-trial (out-of-court) procedure for appealing decisions and actions (inaction) of the Federal Tax Service

As we have already noted, the objects being inspected have the right to appeal against the actions (inaction) of an official of the Federal Tax Service, as well as the decisions they make in a pre-trial (out-of-court) procedure.

The inspected objects have the right to file an appeal (complaint) orally or send a written appeal (complaint) by mail, including in the form of an electronic document to the official website of the Federal Tax Service, management on the Internet and report a violation of their rights and legitimate interests, unlawful decisions, actions (inaction) of specialists of the tax inspectorate, violation of the provisions administrative regulations, incorrect behavior or violation work ethics. If necessary, to confirm its arguments, the inspected object shall attach documents and materials or their copies to the appeal (complaint).

In conclusion, I would like to note that control and supervision over the completeness of accounting for cash receipts in organizations and individual entrepreneurs in the form in which it is prescribed administrative regulations, differs significantly from the usual checks by banks of compliance with cash discipline. This difference lies in the fact that, in addition to directly observing cash discipline in the usual sense, both CCP and BSO and the completeness of revenue accounting are checked. In addition, the registers of both accounting and tax accounting are studied.

Separately, the question arises about the frequency of the inspections under consideration. If, before 2012, cash discipline checks were carried out by banks regularly once every two years, how often will the Federal Tax Service conduct such checks?

And another equally important issue, which is not mentioned in administrative regulations: What period will be covered by the checks? According to Art. 4.5 Administrative Code of the Russian Federation A ruling on a case concerning an administrative offense cannot be issued after two months have elapsed from the day the administrative offense was committed. It can be assumed that the tax authorities, when checking the completeness of accounting for cash proceeds, will be limited to two months for the purpose of bringing to responsibility under the Code of Administrative Offenses of the Russian Federation. But the option seems more likely, according to which the audit will cover more a long period- three years preceding the year of the audit. It is this period that can be checked as part of an on-site tax audit ( paragraph 4 of Art. 89 Tax Code of the Russian Federation). If there are violations, the inspectors will be held liable under the Code of Administrative Offenses of the Russian Federation, and data on violations that led to an underestimation of the tax base will be information for analytical work and the preparation of an on-site tax audit. While this question remains open, we will receive an answer to it as soon as the checks begin.

Electricity consumption without a contract: how to avoid negative legal consequences. Organizer: Higher School of Public Audit of Moscow State University