Apple of discord: PBU 22/2010 obliges to correct financial statements if there is an error, but there are no fields for correction in the forms and it is not clear whether to submit “clarifications”.

Why is this important: for distortions in reporting, inspectors have the right to fine the company 10 thousand rubles (Clause 1 of Article 120).

PBU 22/2010* provides new order correction of errors in financial statements. It is not clear from it whether it is necessary to clarify the annual reporting if an error in it was discovered after submission to tax office. Colleagues argued about this on the forum www.forum.glavbukh.ru, but did not come to a consensus.

VERSION No. 1

THE ERROR IS CORRECTED IN THE CURRENT REPORTING

Some colleagues felt that it was not necessary to correct the balance already presented and other forms. When inaccuracies are discovered after reporting to the inspectorate and statistics service, they must be corrected during the discovery period. And if the inaccuracy relates to previous year, then in the balance sheet for the current period it is necessary to change the opening one.

Only if, due to an error, the tax reporting, for example, for income tax, you need to submit updated returns for the previous year.

VERSION No. 2

AN ERROR IS REPORTED BY A HELP WITH EXPLANATION

Other participants in the discussion also came to the conclusion that there is no need to submit updated financial statements to the inspectorate. But if errors are identified, you will need to submit a special certificate to the Federal Tax Service.

It can be compiled in free form. It should explain in which lines of the balance sheet and other forms of reporting errors were made and by what amount each incorrect indicator changes. This will exempt the company from a fine for violating accounting rules under Article 120 of the Tax Code of the Russian Federation, and the director - from administrative fine under Article 15.11 of the Code of Administrative Offenses of the Russian Federation.

VERSION No. 3

IT IS ENOUGH TO REPLACE REPORTING

Still others in the dispute believed that the balance sheet, profit and loss account and other forms could be replaced. True, this can only be done if they have not expired deadlines submission of reports, that is 90 calendar days at the end of the year (clause 2 of article 15 Federal Law dated November 21, 1996 No. 129-FZ). After this period, errors must be corrected this year.

OPINION "UNP"

CLARIFY THE REPORTING IN THE EVENT OF A SIGNIFICANT ERROR

IN accounting policy Each company establishes which errors are significant for it and which are not. Minor errors do not require correction. And no liability is provided for this. But reports submitted with significant errors must be replaced. Provided that it has not yet been approved by the participants or shareholders. “Clarifications” must be submitted to both the statistics service and the tax office.

The essence of the errors must be disclosed in the revised statements. PBU 22/2010 and order of the Ministry of Finance of Russia dated 07/02/10 No. 66n do not determine how to do this. After all, the forms do not have a field for the correction number. In our opinion, the reporting must be compiled correctly, and on paper. Otherwise, those who report electronically will not be able to submit a second report. This was confirmed to us by local tax officials. The fact of errors must be recorded in explanatory note. And attach to the corrected reporting covering letter. This will explain the reason for retaking the exam.

After approval, there is no need to clarify the reports, but significant errors must be corrected in the current reporting by recalculating the indicators of previous years (clauses 7-9 of PBU 22/2010).

PBU 22/2010.

In any case, the error correction is issued accounting certificate, in which you must indicate:

when and what mistake was made;

which reporting lines and in what amount were affected by the error and why it was considered significant;

when an error is detected;

what transactions corrected the error;

which reporting lines have been adjusted, including retrospectively.

Situation 1. An error was identified before the reporting was approved by the organization’s participants. The error must be corrected by entries on December 31 of the reporting year. To do this, incorrect wiring must be done and, if necessary, correct entries. In addition, everyone who was provided with the original version of the report must be sent a revised version. clause 7, PBU 22/2010.

Example. Correction of a significant error identified before the statements were approved

Worker bonuses production workshop in 2016 were charged in the correct amount, but incorrectly posted - D 26 " General running costs" - K 70 "Settlements with personnel for wages" instead of posting D 20 "Main production" - K 70. As a result, the amount of bonuses is incorrectly reflected in the report financial results for 2016 instead of line 2120 "Cost of sales" on line 2220 "Administrative expenses". The error was discovered in March 2017 after the reporting was submitted to the organization’s participants for approval.

To correct the error, the following entries were made on December 31, 2016:

In the amended version of the financial results statement, signed by the head and presented to the participants of the organization, the amount of bonuses is reflected in line 2120 “Cost of sales”.

Situation 2. An error was discovered after the reporting was approved by the organization’s participants. Then the error in choosing an organization is corrected clause 9 PBU 22/2010:

or records as of the date the error was discovered;

or records as of January 1 of the year in which the error was discovered. This is convenient because on January 1, as a rule, there are no other accounting entries and entries for correcting errors will be immediately visible to the accountant. However, this can only be done if the organization does not represent interim reporting users.

Approved financial statements of previous years cannot be corrected. Errors are corrected retrospectively clause 9, , , PBU 22/2010, Letter of the Ministry of Finance dated 02/08/2016 N 07-01-09/6117. That is, in the current year's reporting, data for years in which errors were made are reflected as if there were no errors. In the explanations to the reporting for the current year, you need to write why the reporting data for previous years has changed.

The procedure for correcting such errors depends on whether the error affected the financial result.

Option 1. The error simultaneously affected the following indicators.

From 07/01/2017, the invoices appeared new line 8 "Identifier government contract, contract (agreement)". Naturally, you only need to fill out this information if it is available. IN otherwise this line can simply be left blank.

Obtaining property tax benefits has been simplified

Co next year citizens entitled to benefits on property, transport and/or tax land tax, you will not have to submit documents confirming your right to benefits to the Federal Tax Service.

We simplify the use of PBU 18/02

PBU 18/02 is perhaps one of the most difficult. For each transaction, the accountant calculates temporary or permanent differences. Then - SHE, IT, PNO or PNA. However, there is an alternative approach in which you can do without complex calculations.

Adjustment balance for tax 2017

The obligation to submit financial statements to the tax office is established for all organizations (clause 5, clause 1, article 23 of the Tax Code of the Russian Federation). How and when can you submit the corrective balance to the tax office? We'll talk about this in our consultation.

Clarifying the balance: right or obligation

The rules for drawing up a balance sheet are established not by tax legislation, but by accounting legislation. At the same time, current legislation in the field accounting does not allow corrections to financial statements already approved by the owner.

Therefore, we further proceed from the fact that the reporting has not yet been approved by the owners, because only in this case can corrective reporting be drawn up. Although here, not everything is so simple: whether or not to draw up an adjustment balance depends on the nature of the detected error.

Thus, if a significant error is identified in the balance sheet submitted to the tax office, it is corrected in the corresponding accounting accounts in December of the reporting year (clause 8 of PBU 22/2010). Once the error is corrected, new financial statements are prepared, called restated financial statements. IN machine readable form submitted to the tax office, you must fill in the “Adjustment number” field with the value “1- -”. If the statements are not prepared on machine-readable forms, then it is necessary to indicate in them that they are revised.

This revised reporting must be resubmitted to the tax office, as well as to all other authorities where it was previously submitted (participants, Rosstat authorities, etc.).

Moreover, if the financial statements are not resubmitted, if there is a significant error, it is necessary to recalculate the comparative indicators in the statements. This means that in current reporting, the indicators of the previous period should be reflected as if the error had never been made. This is called a retrospective recount.

Let us recall that a significant error is an error that, individually or in combination with other errors, can affect economic decisions users, accepted by them on the basis of financial statements (clause 3 of PBU 22/2010). The procedure for determining the level of materiality depending on the size of the error and its nature is established by the organization (for example, a distortion of 10% or more of any reporting item).

If the error is insignificant, then the tax accounting reports submitted are not resubmitted, and the identified errors are corrected in the current reporting period.

Those organizations that have the right to apply have the right, even if there is a significant error in reporting, not to retake it, but to correct the error itself in the month of discovery. They are not required to make a retrospective recalculation of their financial statements.

By March 31 of the year following the reporting year, all legal entities without exception are required to submit a set of financial statements to the Federal Tax Service, as well as to Rosstat. It is assumed that at the time of filing the reports are prepared in accordance with all the rules current legislation, simply put, is reliable. However, sometimes errors still occur in such documents, and then a completely reasonable question arises: is it possible to submit an updated balance sheet and adjustments to the financial statements in all other forms?

Dates of signing and approval of financial statements

Maintaining accounting records is everyone’s responsibility. legal entity. According to the results calendar year the totality of the company’s performance indicators during a given reporting period is drawn up in the form of a set of financial statements, which are submitted to the regulatory authorities. At all balance sheet and other forms as part of such reporting are a reflection of the company’s activities, which take into account absolutely everything business transactions companies, including those that are not relevant for the calculation of various taxes depending on the tax system applied by the company.

Responsible for the preparation of financial statements is Chief Accountant company, signs it CEO. In addition, the annual financial statements, as follows from the provisions of paragraph 9 of Article 13 of Federal Law No. 402-FZ, must be approved by the owners of the company. In accordance with Article 33 of the Federal Law “On Companies with limited liability» approval of the balance sheet, profit and loss statement and other forms as part of the LLC’s reporting is within the competence of the general meeting of the company’s participants. JSCs approve their annual reports general meeting shareholders in accordance with the provisions of Article 48 of the Federal Law “On Joint Stock Companies”.

Interestingly, the deadline for submitting financial statements to the Federal Tax Service is March 31 of the year following the reporting year. At the same time, for the approval of reporting by the owners of the company, separate terms. Thus, the founders of an LLC must approve the annual reporting strictly in March-April, the shareholders of a JSC can do this from March to June inclusive. It's about, of course, about the periods after the end of the reporting year. Thus, although it is assumed that already approved financial statements are submitted to the Federal Tax Service, in fact their approval by the owners may take place somewhat later. At the same time, the annual meeting of founders or shareholders that was not held at the time of submitting reports to the Federal Tax Service does not relieve the company from the need to fulfill its reporting obligation to the Federal Tax Service within the specified period.

Updated financial statements

But let’s return to the question of whether it is possible to submit an adjusting balance sheet if in the past reporting period some errors were identified that affected the data presented in the report.

Based on the postulates of PBU 22/2010 “Correcting errors in accounting and reporting”, approved by Order of the Ministry of Finance dated June 28, 2010 No. 63n, the possibility of adjustment financial statements depends on the moment at which the error was detected. Everything depends on this possible situations detection of errors in accounting that lead to distortion of financial reporting data for the year can be divided into several options. In some of them you can submit a balance adjustment, in others this is not required.

The most simple situation– if accounting errors were identified before the end of the calendar year. Detected data distortion is corrected by the corresponding posting to the accounts of the accounting department in the month of the reporting year in which it was detected. Balance sheet adjustment for 2016 such a case there will be no need to conduct it, because the annual report will initially be correct, since it is compiled as of December 31, that is, it will already contain the necessary corrections.

A similar situation occurs if an inaccuracy is discovered during the preparation of annual reports before they are reviewed by the company’s owners and submitted to the Federal Tax Service, that is, strictly in January-February. In this case, paragraph 6 of PBU 22/2010 requires corrections to be made in the accounting registers in December of the year for which the report is being prepared. In this case, the annual financial statements will also be drawn up correctly from the beginning, and there will be no need to submit an updated balance sheet.

It is worse if unaccounted for or distorted data was discovered after the financial statements were signed by the manager and transferred to the Federal Tax Service. If this happened before the documents were approved by the meeting of shareholders or founders (for example, in April), then the company is obliged to make appropriate accounting corrections in December of the reporting period and replace the financial statements already submitted to the regulatory authorities (clause 7 of PBU 22/2010). Thus, in in this case you will have to prepare and file an adjusting balance and other forms. It is this set of reports that will be reviewed and approved by the company’s owners at annual meeting.

If an error is identified during the meeting, but before the approval of the annual reports, then it will have to be revised (clause 8 of PBU 22/2010). Simply put, errors in accounting are also corrected in December, the previously prepared set is replaced with a corrected one, and corrective accounting statements are submitted to the Federal Tax Service. However, the revised package must disclose that this version reporting replaces the one originally submitted, as well as the reasons why this happened.

In a situation where errors in the accounting of the past year were discovered after the reports were submitted to the Federal Tax Service, as well as after their approval at the annual meeting of owners, the financial statements for last year is not subject to revision (clause 10 of PBU 22/2010). So the answer to the question of whether it is necessary to submit updated financial statements in such a case will be negative. A distortion of accounting information that was discovered, say, in July, needs to be corrected in the current period of its discovery. Thus, the accountant will have to adjust the data generated at the beginning of the year for account 84 “ retained earnings (uncovered loss)" in correspondence with the account for which the inaccuracy of the previous year was identified.

The concept of materiality of an accounting error

All of the situations described above, in which an accountant has to face the problem of how to submit an updated balance sheet, assume that the errors that led to the distortion of data are significant. The concept of materiality is defined in paragraph 3 of PBU 22/2010.

Thus, an error is considered significant if it is individually or in combination with other errors for the same reporting year may influence decisions made on the basis of these financial statements. A good example similar situation– the issue of paying dividends to founders or shareholders depending on performance annual profit, the size of which may be distorted due to such an error. However, it is interesting that the company has the right to determine the degree of significance of the error itself, based on the value of indicators of certain accounting items. In this case, the materiality criteria must be enshrined in the accounting policies of the organization.

If the identified error is not significant, then, regardless of when it was made, the organization has the right to make corrections in the month it was discovered. This means that in such a situation, the company does not have to submit an updated balance sheet, regardless of whether or not it was approved annual reporting founders or shareholders of the company. For example, if we are talking about an insignificant error made in the accounting of 2016, then even if it is identified in April 2017, a balance sheet adjustment for 2016 will not have to be submitted. Incorrect data will also need to be corrected in April. In this case, the profit or loss that could arise as a result of correcting such minor error, should be reflected as part of other income or expenses of the current period.