2-NDFL and 6-NDFL: Federal Tax Service talks about typical mistakes

What programs are used to check personal income tax reporting?

You can check Form 6-NDFL as follows:

• Built-in 1C check - checks the main control ratios in 6-NDFL (except for inter-documentary ones).
• Inter-document relationships – manual control only.

To check 2-NDFL the following are provided:

• Built-in 1C check - identifies errors in personal data in 2-NDFL.
• Tester program – carries out format control.
• Taxpayer legal entity – checks the “mathematics” in 2-NDFL (free program).

If there are discrepancies in the forms

Before sending the document, it is recommended to carry out the reconciliation yourself using the given ratios. Let's assume that the accountant finds a data discrepancy. In this case:

1. Check the forms for typos.
2. Find out which value is correct - in the certificate or in the calculation.
3. Correct the identified inaccuracy and make adjustments for previous periods, if necessary.
4. Correct your accounting records.

If a discrepancy is found in a report that has already been submitted, an adjustment must be submitted to the Federal Tax Service. There is a way to explain tax discrepancies in 6-NDFL and 2-NDFL - send a letter to the inspectorate with explanations and indicate the reasons for the discrepancies.

Checking “mathematics” in 2-NDFL

You can check the “mathematics” (compliance of the calculated tax with the tax base, etc.) in 2-NDFL using the Legal Entity Taxpayer program.

You can download the Legal Entity Taxpayer program on the nalog.ru website using the link →

When you start working with the program, you will need to fill out information about the organization, then download the file with 2-NDFL certificates from the 1C program and upload it to Taxpayer Legal Entity.

After launching the check, its results in the Taxpayer Legal Entity can be displayed in the following form:

The most valuable thing about the program is that it tests “mathematics”. For example, it compares:

• the amount of personal income tax calculated in the 2-NDFL with the calculated personal income tax calculated;
• the amount of personal income tax transferred and withheld (personal income tax transferred should not exceed the withheld tax);
• the amount of personal income tax withheld with the estimated personal income tax withheld.

Data reconciliation 6 personal income tax 2 personal income tax

What ratios are checked in the reports:

1. The value of column 020 of Form 6 of personal income tax is equal to the sum of the total income of all employees with attribute “1” in the certificate at the same tax rate.
2. The value of column 025 from the report is equal to the sum of the total dividends from 2 personal income taxes with the attribute “1” of all employees for the year.
3. The value of column 040 of 6 personal income tax is equal to the amount of the total calculated tax from the certificate with attribute “1” with the same rate for all personnel.
4. The value of column 080 from the report is equal to the amount of tax not withheld by the employer from the certificate for all personnel for the year.
5. The value of column 060 from the report is equal to the sum of all certificates with the attribute “1” for the year.

For reference! Sign 1 means that the certificate contains information about all employees who received income from the employer.

At the same time, characteristic 2 contains only those employees from whose income tax was not withheld. They must be reported so that the inspectorate sends them letters about the need to independently pay the tax with the submission of the 3rd personal income tax return.

Control ratios 6-NDFL and 2-NDFL

Inter-documentary relationships between 6-NDFL and 2-NDFL will have to be checked manually.

The general verification scheme for data lines 6-NDFL and 2-NDFL is as follows:

At the same time, line 070 (the amount of personal income tax withheld) and line 090 (the amount of personal income tax returned) of the 6-personal income tax are not involved in the verification due to special rules for filling them out.

In order to obtain summary data on 2-NDFL , you can print the Register (additional since 2014) (Print – Register (additional since 2014):

It will be presented in the following form:

In the report you can see the amount of income and calculated personal income tax as a whole for all individuals, which must be compared with 6-personal income tax .

2-NDFL and 6-NDFL: Federal Tax Service talks about typical mistakes

No later than April 3, tax agents must submit to the tax authorities annual forms on the income of individuals - certificate 2-NDFL and calculation 6-NDFL. Vladislav Volkov, head of the personal income tax department of the Department of Taxation of Personal Income and Administration of Insurance Contributions of the Federal Tax Service of Russia, spoke about common questions and the most typical errors in the preparation of these reports BUKH.1S

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New income and deduction codes

By order of the Federal Tax Service of Russia dated November 22, 2016 No. ММВ-7-11/ [email protected] new codes of income and deductions were approved. The changes came into force on December 26, 2016.

New codes for standard tax deductions have been introduced (126-149).

Changes have been made to income codes 1532, 1533, 1535 regarding income from transactions with derivative financial instruments

New income codes 1544-1549, 1551-1554 have been introduced regarding income received from transactions with securities and transactions with derivative financial instruments accounted for in an individual investment account. In this regard, existing deduction codes have also been clarified and new deduction codes have been introduced.

Information on form 2-NDFL must be submitted with new codes for 2016. However, if the codes in this certificate are presented without taking into account the latest changes, no penalties will follow.

New reward codes

Two new bonus codes have been introduced.

Code 2002. Amounts of bonuses paid for production results and other similar indicators provided for by the laws of the Russian Federation, employment agreements (contracts) and (or) collective agreements (paid not at the expense of the organization’s profits, not at the expense of special-purpose funds or targeted revenues ).

Code 2003. Amounts of remuneration paid from the organization’s profits, special-purpose funds or targeted income.

The Ministry of Finance issued clarifications that the date of actual receipt of income from premiums is the date of direct payment of such income or transfer to the account of the taxpayer - an individual. In 2015, the Supreme Court of the Russian Federation issued a ruling dated April 16, 2015 No. GK15-2718, which stated that bonuses related directly to wages are paid in the same way as wages. And, therefore, the date of actual receipt of income from bonuses related to wages should be considered the last day of the month for which it was accrued. After this, there was no official clarification from the Ministry of Finance that its position was changing. However, earlier the Ministry of Finance itself indicated that if the determinations of the higher courts go against its position, then the position of the courts is accepted.

Changes in reporting under Federal Law No. 113-FZ dated May 2, 2015

The most important errors when filling out reports are related to the dates of actual receipt of income.

Below are dates for specific types of income.

Date of personal income tax withholding for material benefits

Previously in paragraph 2. Article 231 of the Tax Code of the Russian Federation stated that the tax agent withholds personal income tax until it is fully withheld, even from payments next year. Now this provision has lost force; after the tax agent reports the impossibility of withholding personal income tax, his obligation to withhold ceases.

Therefore, if before December 31, for example, there were no payments in cash for material benefits or income in kind, a 2-NDFL certificate with sign 2 is sent. But there is a nuance regarding the date of tax withholding associated with material benefits. For example, if an employee took out a loan to buy a home. He receives monthly income in the form of material benefits. According to today's legislation, if on December 31 the salary for December is not paid, then a tax arises on the benefit that cannot be withheld. But there is a way out. If the date of receipt of income from other cash payments falls on the last day of December, income tax can be withheld from this payment in the form of a material benefit. How have you always done it? According to the financial benefit, tax was withheld from this January salary for December. The same can be done today. The date of actual receipt of income from the December salary falls on the 31st, and no matter what was not paid, you can deduct from the same amount. This will probably be better than submitting certificates with feature 2 every year.

Deadline for transferring personal income tax for certain types of income

Many tax agents put in line 120 of the 6-NDFL reporting the date when the tax was actually transferred. It is not right. Of course, there is no need to wait until the last day of the month to make the transfer. If, for example, vacation or sick leave was paid on the 15th, withheld on the 15th and transferred on the 15th, this is not a violation. But in 6-NDFL, the deadline for transferring vacation pay tax must be set to the last date of the month. That is, line 100 is the 15th day, line 110 is the 15th day, line 120 is the last day.

For section 2, there is a certain formula for self-control - the amount of tax on line 140, reduced by 090, should fall into the budget between lines 110 and 120. That is, from the date of tax withholding to the date of tax remittance. If it “falls” ahead of schedule, it will not be counted. If a debt arises, the tax authority will make demands.

The ratio of sections 6-NDFL and 2-NDFL

Certain relationships of values ​​between reporting documents will be controlled by tax authorities. In particular, section 1 of the 6-NDFL calculation must be equal to 2-NDFL (or section 2 of the income tax return). Section 2 6-NDFL must be equal to tax transfer + CRSB (actual transfer).

In this case, sections 1 and 2 do not correspond. The sum of 140 lines may not coincide with the sum of 070 lines; there is no such control ratio.

Interdocumentary control ratios

Line 020 6-NDFL at the corresponding rate (line 010) = Line “Total amount of income” at the corresponding rate of 2-NDFL certificates with prize 1, submitted for all taxpayers + Line 020 at the corresponding rate (line 010) of appendices No. 2 to the declaration on income tax, presented for all taxpayers.

Line 020 does not include amounts that are not subject to tax. For example, severance pay upon dismissal, if it does not exceed three times the salary. And if it exceeds, then only the amount of this excess enters 020. There is no separate code for this excess; in 2-NDFL you need to enter 4800.

Line 025 6-NDFL = Income in the form of dividends (income code 1010) of 2-NDFL certificates with sign 1, presented for all taxpayers + Income in the form of dividends (income code 1010) of appendices No. 2 to the DNP, presented for all taxpayers.

If line 025 is filled in, then this amount must be included in line 020.

Line 040 6-NDFL at the corresponding rate (line 010) = line “Tax amount calculated” at the corresponding rate of 2-NDFL certificates with attribute 1, submitted for all taxpayers + Line 030 at the corresponding rate (line 010) of Appendix No. 2 to the DNP, presented for all taxpayers.

There is a formula for controlling the amount of calculated tax, where the value of line 020 (the amount of accrued income) minus the amount of tax deductions (030), multiplied by the rate, is equal to 040. Sometimes tax authorities require compliance with this formula without reading about the discrepancies. It is not right. This formula may not converge, and this is stated in the control ratios. Because, firstly, in our country not all income is considered a cumulative total, and secondly, after all, 6-NDFL is a consolidated form for all taxpayers. And 040 should not be calculated by empty multiplication according to the formula, but precisely as the calculated tax for each taxpayer.

Line 080 6-NDFL = Line “Tax amount not withheld by the tax agent” of 2-NDFL certificates with attribute 1, submitted for all taxpayers + Line 034 of Appendix No. 2 to the DNP, submitted for all taxpayers

080 clearly includes only those amounts that the tax agent cannot withhold during the tax period. As for the rolling salary between reporting periods (for example, March-April), it does not need to be placed there. You can keep it in the next quarter.

Line 060 6-NDFL = Total number of 2-NDFL certificates with sign 1 and appendices No. 2 to the DNP, submitted for all taxpayers by this tax agent

It will not be the number of pieces of paper that will be added up, but the number of people – taxpayers. At the same time, I would like to remind you that income from securities is reflected precisely in the income tax return, Appendix 2. And there is no need to duplicate this data in 2-NDFL. As for dividends, they are indicated in Appendix No. 2 to the DNP only for securities. Dividends in LLCs from equity participation are reflected only in 2-NDFL.

Line 070 does not participate in inter-document control relationships. It will not fit in with either 2-NDFL or Appendix No. 2 to the DNP, because the very indication of the amounts in 070 and the amounts of withheld tax in 2-NDFL are different. In 2-personal income tax it goes for the period, in 6-personal income tax - in the period. Therefore, in line 070, the amount of tax withheld is entered only in the reporting period when it was directly withheld. If there were no payments (example with the transfer of salaries between quarters), then the amount is not entered in 070, because it was not withheld.

Form 2-NDFL: filling out

A common mistake is when tax agents do not wait for a notification from the Federal Tax Service confirming the right to reduce tax on fixed advance payments. If you have not received a notification, then the amount of fixed payments in 2-NDFL is not reflected in principle. Sometimes they are indicated in advance, knowing that a notification is about to arrive. And this is unreliable information.

The TIN in 2-NDFL may not be indicated if the tax agent does not have information about the taxpayer’s TIN.

How to indicate tax rates when recalculating Russian residence? In general, there should not be two sections - 30% and 13%. These two sections can occur if a non-resident is working - a highly qualified specialist, whose entire income is not taxed at 13% (clause 3 of Article 224 of the Tax Code - all kinds of gifts and material assistance will be taxed at 30%).

In 2-NDFL and 6-NDFL it is strictly forbidden to indicate negative values. Sometimes this is done during recalculation, when a person is recalled from vacation, or he brought sick leave. All reversals and all recalculations must be done in accounting registers. In 2-NDFL the final amount of income is indicated.

For what period in 2-NDFL and 6-NDFL should I indicate lost wages? For example, if salaries for November and December are paid in March and April. In 2-NDFL it is indicated for the period in which it was accrued. In 6-NDFL, under section 1, these amounts will go the same way as in 2-NDFL - according to accrual, and under section 2 - based on actual payment. With such filling, of course, one should expect a notification from the tax authority to provide explanations, because this is a clear violation of labor laws. We should not be afraid, but explain the situation to the tax authorities.

2-NDFL – provision of corrective and canceling information.

Canceling information with code 99 is presented only if the certificate should not have been submitted in principle, or it was submitted erroneously.

Nowadays, banks sometimes write off customer debts without having yet exhausted all options for debt collection. The written-off debt, accordingly, is designated as the borrower’s income and they rush to tax it. And then suddenly a miracle happens and the borrower repays the debt. Consequently, there is no income, it is canceled - sign 99.

If you made a mistake in the total values, you do not need to cancel the certificate. It should simply be submitted as a clarification. If you need to clarify your identification data, you can also submit a corrective certificate, but along with it you must submit a corresponding statement explaining what exactly is changing.

Overpayment of personal income tax can now be counted against arrears, including other taxes

In February, there was a positive shift for taxpayers associated with the return of overpaid personal income tax.

Previously, the Ministry of Finance took the position that overpayment of personal income tax is subject to refund only and cannot be counted against future payments. But in February, a letter was issued according to the tax authorities system - No. ГД-4-8/2085 dated 02/06/2017 about offsets of such amounts. Finally we got it.

True, automatic offset against future periods is not provided. The overpayment can be offset against the arrears - both personal income tax and other federal taxes. As well as vice versa, you can count the overpayment of other taxes against the arrears of personal income tax. The letter applies not only to future periods, but also to past periods.

The procedure is the same as for returns. It is necessary to submit extracts from tax registers, payment documents, and other documents confirming that this is an excess amount. An on-site inspection is not required here.

You can simplify the procedure a little for yourself. For example, if you pay vacation pay on the 15th, then the tax on it must be paid before the last date of the month. Write an application to offset the overpayment against this tax between the 15th and last day of the month. In this way we bypass clause 9 of Art. 226 of the Tax Code, due to which it is impossible to offset the overpayment automatically.

Control ratios 6-NDFL and RSV

6-NDFL and DAM reports :

It may not be fulfilled if the organization pays income not subject to personal income tax.

For example, in line 020 6-NDFL report, will not be reflected, but in line 030 of Appendix 1 of the report on insurance premiums:

• child care allowance up to 1.5 years;
• maternity benefits;
• sick leave accrued in December 2022 but paid in January 2022

To find the differences between 6-NDFL and RSV, see our life hack - How to find the difference between the amounts in 6-NDFL and RSV

Those. These control ratios may indeed not be met and this is normal. However, in this case, the Federal Tax Service will have to provide explanations about the reasons for their non-compliance.

See - An example of a response to the requirements of the Federal Tax Service to provide explanations for discrepancies in the 6-NDFL and Calculation of insurance premiums reports

How to check reference ratios

The Federal Tax Service letter No. BS-4-11/ explains how to compare and which lines should match in 2-NDFL and 6-NDFL in 2022 - now there is no 2-NDFL report, and certificates of income and taxes are submitted as part of the annual calculation . This means that when checking the form, you need to look at the internal document control ratios of 6-NDFL in 2022.

. The appendices to the regulatory document contain the following data in the form of detailed tables:

• control ratio between indicators;
• links to the relevant articles of the code that are violated;
• description of the potential error;
• instructions for regulatory authorities on what actions to take if the described error is detected.

Verification indicators are divided into 5 groups - intra-document and inter-document for budget payment cards, tax reporting, information resources and bank accounts. The procedure for reconciling 2-NDFL and 6-NDFL for 2022 depends on the new rules for filling out the calculation. The tax agent checks only the first group of indicators - intra-document KS. We remind you that a separate 2-NDFL report is not submitted in 2022, but reference information is provided as part of the calculation of personal income tax amounts for the 4th quarter, that is, at the end of the year. There is no need to fill out application certificates in reporting forms for quarters 1-3.

IMPORTANT!

Reconciliation of forms using control ratios is the right, not the responsibility of the tax agent. But if the inspector discovers an error when checking the calculation, he will send a request for explanations.

We have prepared a table of control ratios of 6-NDFL and 2-NDFL for 2022, taking into account the new rules for filling out the calculation. These are excerpts from letter No. BS-4-11/; for a complete list of intra-document and inter-document inspection indicators, see the explanatory document from the Federal Tax Service.

ConsultantPlus experts looked at how to reflect various payments in the calculation of 6-NDFL. Use these instructions for free.

Control ratios for checking employee salaries

Letters of the Federal Tax Service of Russia dated October 17, 2019 N BS-4-11/ [email protected] and dated January 17, 2020 N BS-4-11/ [email protected] introduced new additional control ratios for 6-NDFL and DAM .

Now the salary amount will be checked:

1. The average salary of each employee is >= minimum wage.
2. Average salary for the entire organization >= Average industry salary for the region for the last calendar year.

The first control relationship may not be satisfied when, for example, an employee:

• works part-time;
• the period was not fully worked out due to the employee’s absence due to illness, leave at his own expense, etc.

Therefore, you need to be prepared for the fact that the tax office will ask for clarification about non-compliance with these control ratios.

Reporting Differences

Legal entities and individual entrepreneurs with an official staff (even if it has only 1 employee) are required to calculate and withdraw tax from the income of individuals and transfer it to the state treasury. These transactions must be reported to the Federal Tax Service using two established forms:

• personal income tax report 6;
• certificate 2 personal income tax.

The Federal Tax Service of Russia developed these reports and ordered all employers to submit them within the prescribed time frame. But in addition to them, each business entity submits other documentation:

• DAM – for insurance payments for employees;
• declarations for various taxes or special regimes;
• financial statements.

It is important that the data of the submitted reports correlate correctly with each other and do not contain contradictory information, otherwise the Federal Tax Service will ask for clarification or hold you accountable for providing falsified information, making mistakes, tax evasion, etc.

To verify the correctness of the specified data and their relationship, the Tax Service has provided control ratios. For them, it is required to check the reporting before filing, and for them the inspector will conduct a desk audit.

Control ratios were established by Federal Tax Service letter No. BS-4-11/3852 dated March 10, 2016. The document will save you from offensive fines and will allow you to verify the completeness and accuracy of the data provided.

But before moving on to this letter, I will tell you how 2 personal income taxes and 6 personal income taxes differ.

Table 1. Differences between reports 2 personal income tax and 6 personal income tax.

We recommend additional reading: Taxpayer status in certificate 2-NDFL

Explanations about discrepancies in the RSV and 6-NDFL due to compensation for delayed wages

On August 11, 2022, Romashka LLC received a request to provide an explanation of the reasons for the discrepancies in payments in favor of employees according to the 6-NDFL calculation data for the half-year of 2022 with the data of the calculation of insurance premiums for the half-year of 2022.

On June 15, 2022, Romashka LLC paid compensation for delayed wages for April:

• 180 rub. — I.I. Ivanov;
• 220 rub. — M.I. Ivanova;
• 320 rub. — P.P. Petrov.

In total, they paid compensation of 720 rubles. Compensation does not exceed 1/150 of the key rate, which is in effect during the period of delay, of the amounts not paid on time for each day of delay. Therefore, the LLC did not withhold personal income tax from compensation. Insurance premiums are calculated for the amount of compensation (Article 236 of the Labor Code, clause 1 of Article 217, clause 1 of Article 420 of the Tax Code).

Applications:

• accounting certificate for payment of compensation for delayed wages.

Difference in meanings by shape

When preparing reports for the fiscal authority 2-NDFL and 6-NDFL, what is the difference between the information specified in the two documents will allow you to correctly fill out the required declarations. The issue of discrepancy lies in the different meaning of total deductions for income reflected in the reporting documents for personal income tax due to the fact that part of the deductions from the payroll fund in one report is reflected in the reporting year, and in another tax report the amount flows into the new reporting period.

There is no need to make corrections or adjust the figures, because December wages are paid in January, which eliminates the inclusion of December tax in line 070 6-NDFL. The provision on this is explained in letters from the fiscal authority, issued under numbers BS-4-11/ [email protected] and BS-4-11/23138, at the end of 2016.

You should understand how 6-NDFL differs from 2-NDFL based on tax calculations for December in order to make the correct calculations:

• Personal income tax for December is not included in the annual report for 6-NDFL;
• 2-NDFL will reflect the amount of tax withheld and transferred, regardless of the fact that the required amount was withheld a month later.

Otherwise, the accountant is recommended to adhere to those published in March 2016. separate explanatory letters from the Tax Service regarding the relationships to monitor the correctness of the information entered in the declaration with a comparison of line-by-line values.