Salary commissions in tax 2017: how to protect your salary

We found out how payroll commissions work in the tax office. Since 2017, the approach of tax authorities will change. We will tell you how to protect your salary and how to behave on salary commissions.

Get ready for a salary commission - they now call every third company. It is dangerous to come without preparation, and even more so to ignore. Our correspondent was convinced of this by visiting the commission. How it goes and how to prepare, find out in the special project. A new service on the magazine's website will help you prepare explanations.

Salary commissions are no longer just a formality. The Federal Tax Service ordered subordinates to intensify work in this direction (letter dated June 9, 2016 No. ED-4-15/10246). This year, inspections need good personal income tax indicators, and from next year also on contributions. Therefore, they can be called to the tax office at any time. In the letters of challenge, there were specific amounts to which it is necessary to reach the salary. In addition to explanations, the tax authorities demand to bring with them orders with increased salaries.

You will definitely be called if the company:

• salary below the regional minimum wage or industry average wages in the region;
• personal income tax payments decreased by 10 percent or more compared to the previous year;
• have income tax debts.

Read this article to be ready for commission. At the end, four sample explanations for different salary situations. But it's easier to use the new service " Explanation Wizard". In it, you can design your own explanation for the salary commission. Fill in the fields, check the boxes and click the "Create explanation" button. The service will create a text that is suitable for your company. Save the file to your computer, edit if necessary, and print.

First you will be asked to tell about the company

Moscow, September 29, 10.30, tax office in the city center. The payroll accountant and the Glavbukh correspondent, under the guise of an assistant accountant, enter the inspector's office.

INSPECTOR: Hello. My air conditioner is on, is it blowing for you? Then take a seat. Tell us who you are and what the company does.

ACCOUNTANT: A new company, we have been working since November last year. The call says that you need to bring documents about the legal address. I brought the lease. We have a small office for storing documents. Almost all workers are homeworkers.

So they would write in the explanations that the company is in its infancy. All information from the tax, funds, letters flows to the legal address.

And what are the plans?

If we find a room on the territory of your inspection, we will conclude a new contract. If not, we will look for other options.

So you like us?

I like it, of course. Excellent inspection, next to the subway.

Continuation of the conversation

Listen to the recording from the commission

Most often, the salary commission is carried out only by tax authorities. Less often there are commissions with the participation of foundations and the prosecutor's office. Such meetings may take place not in the inspectorate, but in the local administration.

The Federal Tax Service requires subordinates to be polite. Therefore, commissions usually pass like a calm conversation. But sometimes the tax authorities behave differently: they accuse the company of gray wages and threaten with sanctions. In such a situation, the right decision is not to engage in a skirmish, but to calmly answer questions. about how your colleagues were met at the commission.

Tax officials always call the director. But judging by the survey, most often managers send the chief accountant to the commission. The director appears at this event twice as rarely. Only 4 percent of surveyed companies send a payroll accountant to the inspection.

If you were invited to a commission with the participation of foundations, local administration and the prosecutor's office, then still call the director with you. And if he can't, get someone from payroll or a lawyer. It's hard to answer alone the questions of three or four people at once. You can get confused, say too much, enter into a skirmish.

Inspectors may request an office lease if there is any doubt that the company is located at the legal address. About the new company, say that it is in its infancy, just started working. The tax authorities will be satisfied with the explanation that you need the address only to receive letters from the inspection, funds and store documents.

Show the inspectors that you are not going to migrate, there is no need for you to move to the territory of another tax office, since there is nothing to hide. But when you talk about a company, you should not describe its activities in too much detail. Additional information will lead to additional questions.

They will ask why low salaries and little personal income tax

Okay, we've sorted out the address. Now tell me why your salary is below the regional minimum wage?

We have homeworkers. Some for an hour a day, some for two. We overlooked that their salary is below the minimum wage.

And what do your homeworkers do?

Calling customers, billing. Some leave, others are accepted.

Continuation of the conversation

Listen to the recording from the commission

Average sectoral salaries are taken by the tax authorities in the regional offices of Rosstat. The inspectors used to calculate the average salary in the company according to the 2-NDFL certificates. And now they are determined by the calculation of 6-personal income tax. The formula is:

The inspector will ask you to explain why the company has a low salary. You can name any reasons - starting with the fact that the company has just started working, and ending with a difficult financial situation due to the crisis.

Sometimes inspectors find fault with civil law contracts. Income under such an agreement can be any. The company is not required to pay the contractor a minimum wage. But the inspectors argue that the contract is essentially a labor contract. Prove that the contract does not meet the criteria of employment. The contractor does not comply with the internal labor regulations, performs certain amounts of work, his functions do not correspond to any of the positions in the staff list.

It happens that some employees work in separate subdivisions in other regions. Inspectors sometimes divide the salary of the head office by the total number and receive a low salary. Explain to the tax authorities that the company has regional divisions.

If the tax authorities called the company for a commission due to personal income tax debt, explain to the inspectors why the debt was formed. For example, there is no money due to the fact that customers do not transfer payment. The decrease in tax payments can be explained by the fact that the company opened new separate divisions and transferred part of the employees there.

They will ask you to tell me when you will raise your salary

Are you planning to raise the wages of your homeworkers at all?

And we have already increased, since September 1. I have attached the new staffing table to the explanations. Only now we are afraid. Suddenly you decide that we used to have envelopes, come back from the exit and charge additional personal income tax for past periods.

How much did you raise? Up to a hundred thousand? You have increased within reason. Solely in order not to appear in the lists of those who are being monitored. For this, we ask for clarifications in order to understand who to go to with a check, and who not. That's what to take from you, from homeworkers?!

Continuation of the conversation

Listen to the recording from the commission

It is not enough for tax officials to find out the reasons for low wages. They should convince you to raise it as soon as possible. If the average salary in the company is below the minimum wage, then the tax authorities will recommend reaching it at least to the minimum wage. In this case, you should not argue with the inspectors. After all, the law requires paying salaries not lower than the regional minimum wage. If the salary is more than the minimum wage, then the tax authorities will ask when you raise it to the industry average.

Discuss in advance with the director what to answer. The options are:

1) we have already raised wages;

2) we plan to raise wages;

3) we cannot raise wages for objective reasons;

4) the company should not raise wages.

Sample explanations for each case are at the end of the article.

The survey showed that one in three companies raised salaries after the commission. Sometimes the director agrees to revise salaries as soon as he receives a call for a commission. Then, along with explanations, immediately bring to the inspection a new staffing table and an order with increased salaries. For inspectors, this is ideal, so you will not be asked about anything further.

If you plan to raise salaries after the commission, then tell the tax authorities from what date. The inspectors are hinting that it is safer to change salaries gradually. A sharp increase indirectly indicates that the company had a gray salary. Although the Federal Tax Service admits that this evidence alone is not enough to charge additional personal income tax (see comment below). In addition, the tax authorities understand that their behavior would discredit the very essence of the commissions. After all, their task is to convince the company to increase salaries.

Another hint that the inspector threw in is that if you don’t take a lot from the company, you don’t have to be afraid of checking. The price of the audit depends on the region, but it is not less than 1 million rubles. In 2016, an average of 6.5 million rubles was collected during an audit.

According to the survey, every tenth company does not raise salaries after the commission, despite promises. But this will not solve the problem - soon you may again be called to the commission and asked to explain why you do not comply with the agreements. You can avoid such an unpleasant situation and not make excuses if you come to the commission without a director. Say that only the leader can make a decision, you don’t know about his plans, but you will definitely pass on all the recommendations of the inspectors to him.

If the company cannot change salaries for objective reasons, then write about them in the explanations. For example, the company's sales have decreased, customers are delaying payment, and expenses have increased.

Finally, you have the right to prove that, with the correct calculation, the salary already corresponds to the industry or minimum wage. Inspectors often accept these explanations and do not demand a pay increase. Bring detailed calculations with you.

If there are personal income tax debts, you can draw up a schedule according to which you plan to pay them off. It is also better to pay off part of the debt in advance and bring a payment to the commission. This will confirm your good faith.

Inspectors don't come with a check ifcompany increases salary after commission

Explains the Federal Tax Service of Russia

At the salary commission, the inspectors recommended that the company raise wages to the industry average level. The company complied with the recommendations and increased salaries. Of course, this may indicate that the company used to pay part of the salary unofficially. But only indirectly. In order to charge a company with a violation, inspectors must collect evidence that workers were paid in "envelopes". You need to know the exact amount of income paid and the date of payment. In practice, inspectors do not schedule field inspections if companies accept the inspection's recommendations.

SERGEY TARAKANOV, Counselor of the State Civil Service of the Russian Federation, 2nd Class

They will warn you that they will check the salaries again

Let's have your explanation. For the future, keep in mind that low-salary organizations are under special control, they are constantly monitored. If you do not want to be pulled, then try to build on the regulations on salary increases.

Yes, now we will follow the regional minimum wage. As soon as it changes, we will immediately raise salaries.

Do not forget that employees are also different. Some people get in so much trouble. They can complain where it is necessary that the salary is small, they do not pay on time.

Listen to the recording from the commission

The commission ends with the fact that the tax authorities fix the agreements. Usually this happens in words, but sometimes they immediately draw up a protocol. They can intimidate that the Federal Tax Service monitors organizations with low salaries. It is often hinted that scandalous workers complain about gray salaries to the prosecutor's office and the labor inspectorate. At the end of the meeting, the inspector can immediately set a date for a new one. But if he sees that you are ready to cooperate, and there is nothing to take from you during the check, he will allow you to send a report on the work done via the Internet.

Letter of the Federal Tax Service of the Russian Federation dated July 25, 2017 No. ED-4-15 / [email protected]“On the work of the commission for the legalization of the tax base and the base for insurance premiums” regulated the activities to control the payment of “shadow” wages (hereinafter - Letter No.  ED-4-15 / [email protected]). At the same time, the departments of the Federal Tax Service for the constituent entities of the Russian Federation were instructed to bring this letter to the lower tax authorities and ensure its application.

From the article you will learn how candidates are selected for an invitation to a meeting of such a commission and what to do when you receive an information letter and notification of a taxpayer's call from the inspection.

For the first time, the rules for the work of commissions of tax authorities on the legalization of the tax base were formulated in Letter of the Federal Tax Service of the Russian Federation dated July 17, 2013 No.AS-4-2/12722. Letter No. 21.03.2017ED-4-15/ [email protected] The Federal Tax Service canceled this letter in terms of organizing the work of commissions on the correctness of the formation of the tax base and the completeness of payment by taxpayers (tax agents) of VAT, corporate income tax, corporate property tax, property tax of individuals, land tax, transport tax, single tax paid under USNO, UTII, ESHN. At the same time, the cancellation did not affect the correctness of the formation of the tax base and the completeness of payment of personal income tax.

Ultimately Letter No.ED-4-15/ [email protected] both of the above letters were canceled and updated rules for the work of the commission on the legalization of the tax base and the base on insurance premiums were established.

The purpose of the commission’s work is defined by the tax department as follows: increase in income from personal income tax and insurance contributions to the budget by inducing taxpayers, tax agents, payers of insurance contributions, in respect of which, in particular, the facts of incomplete reflection in the accounting of business transactions, untimely (incomplete) transfer of personal income tax and insurance premiums, falsification of tax and accounting reports.

Regulations Letters No. ED-4-15/ [email protected] determine the sequence of control measures to identify:

facts of reflection in the tax and financial statements of false information;

• facts of payment of "shadow" wages;
• facts of untimely transfer of personal income tax;
• facts of untimely transfer of insurance premiums;
• employers paying wages below the subsistence level or the minimum wage;
• employers who do not formalize labor relations with employees, as a result of which the tax base for personal income tax and the base for insurance premiums are underestimated.

Stages of work of tax authorities on the legalization of the tax base	Selection of payers whose activities are subject to consideration at meetings of commissions on the basis of information available in the tax authority and information resources
	Carrying out analytical and control measures in relation to payers
	Sending information letters to payers in order to encourage them to self-assess the submitted statements and changes in tax returns, pay off personal income tax debts, insurance premiums and other actions
	Preparation of materials for consideration by the commission
	Consideration of the activities of payers at meetings of interdepartmental commissions
	Monitoring of indicators of financial and economic activities of payers whose activities are considered by the commissions
	Preparation of information in relation to payers who have not taken measures to eliminate the identified violations of the legislation on taxes and fees, in order to: Reconsideration of their activities at meetings of interdepartmental commissions in local self-government bodies of constituent entities of the Russian Federation or interdepartmental commissions established under the administrations of constituent entities of the Russian Federation; Consideration of the issue of appointing an on-site tax audit

If there are grounds for calling the payer to consider his activities at the commission, the tax inspectorate shall notify in writing of the call to the commission of the payer's officials, indicating the time and place of the meeting of the commission.

Commission Selection

The basis for the selection of payers for invitation to the "salary" commission are lists that are formed by analyzing the available information on the financial and economic activities of payers, taking into account the peculiarities of calculating and paying personal income tax, insurance premiums, in the event of, for example, bankruptcy, liquidation of a taxpayer and payer of insurance contributions, etc.

The following groups of payers are subject to selection for consideration at a meeting of the commission:

• taxpayers with a low tax burden on personal income tax paid by individual entrepreneurs;
• taxpayers - tax agents for personal income tax who have tax debts, who have reduced personal income tax receipts by more than 10% compared to the previous reporting (tax) period, who pay wages below the average level for types of economic activity in the region;
• Individual entrepreneurs who have declared a professional tax deduction in the amount of more than 95% of the total amount of income received for the tax period;
• Individual entrepreneurs who have reflected in their VAT returns the proceeds from sales, while declaring income equal to zero in the 3-NDFL form, or who have not submitted such declarations for the relevant period;
• payers of insurance premiums with arrears in the transfer of premiums, who have reduced the receipt of premiums compared to the previous reporting (settlement) period with a constant number of employees, who have reduced the number of employees during the reporting period by more than 30% compared to the previous reporting period, who calculated insurance premiums in previous reporting periods contributions at an additional tariff of 9 or 6%, while applying other tariff rates in the current reporting period;
• payers in respect of whom information has been received from competent sources of foreign states on the receipt by residents of the Russian Federation of income subject to taxation in the territory of the Russian Federation;
• payers in respect of which there is information on the receipt of income contained in the appeals of control and supervision departments, citizens, organizations, and other sources.

Analysis in the preparation of the commission

When preparing materials for consideration at commission meetings in relation to selected candidates, an analysis of indicators of financial and economic activity is carried out, and tax control measures are also carried out.

To analyze the activities of organizations and individual entrepreneurs, which are subject to consideration at the meetings of the commission, the following are used:

• data of information resources (USRN, USRIP, USRLE, AIS "Nalog-3", PIK "VAT", SOUN, etc.);
• information received as part of Art. 93.1 of the Tax Code of the Russian Federation;
• information contained in the media and the Internet;
• information received from credit institutions, law enforcement agencies, the Pension Fund of the Russian Federation, extra-budgetary funds, licensing authorities, customs authorities, municipal authorities, Rostrud, the Central Bank of the Russian Federation, etc.;
• complaints, statements of legal entities and individuals;
• information received from employees, shareholders (participants) of organizations;
• information received from other sources.

AT letter no.ED-4-15/ [email protected] the directions of the analysis are given, and the recommended forms are given in the appendices to it. So, the analysis is carried out in the following areas:

• analysis of accounting data and other information characterizing the taxpayer (tax agent, payer of insurance premiums) (Appendix 1);
• analysis of accounting indicators (balance sheet) (Appendix 2);
• analysis of indicators of the level of wages paid by the tax agent, as well as the fulfillment by him of the obligation to calculate and transfer personal income tax (Appendix 3);
• analysis of performance indicators for the calculation and transfer of insurance premiums (Appendix 4);
• analysis of reporting indicators of individual entrepreneurs (Appendix 5).

Based on the analysis, tax risks are identified, and the summary results of the analysis are reflected in the form recommended in Appendix 6. In addition, in relation to payers selected for consideration of their activities at commission meetings, an analysis of the level of tax burden is carried out (the form is recommended in Appendix 7).

Direction of the information letter

At the stage of preparation for the meeting of the “salary” commission, an information letter can be sent to the taxpayer (tax agent, payer of insurance premiums) (its form is given in Appendix 8 to Letter No.ED-4-15/ [email protected] ).

The purpose of such a letter is to encourage organizations and individual entrepreneurs to independently analyze the results of commercial activities, identify the causes of a low tax burden, a high proportion of professional deductions, underestimate the base for insurance premiums, low wages, pay off debts on personal income tax and insurance premiums, as well as correct errors. (distortions) of tax reporting.

The information letter reflects the facts, deviations, contradictions and other issues identified in the course of preparation for the commission meeting, the answers to which are planned to be received as a result of consideration of the activities of the taxpayer (tax agent, payer of insurance premiums).

In the information letter, the inspectors offer, among other things:

• clarify tax obligations (or obligations to pay insurance premiums) in the manner prescribed by Art. 81 Tax Code of the Russian Federation, including clarifying the amount of the professional deduction, the amount of payments that are not subject to insurance premiums, thereby adjusting the basis for their calculation;
• present the results of the SOUT if the payer calculates insurance premiums at additional rates;
• pay off debts on personal income tax and insurance premiums;
• calculate personal income tax and insurance premiums from incomes actually received by employees of the organization that are subject to taxation;
• conduct a self-assessment of risks in accordance with Order of the Federal Tax Service of the Russian Federation dated May 30, 2007 No.MM-3-06/ [email protected] .

An information letter should be sent in advance - no later than one month before the date of the planned meeting of the commission.

The deadline for making a decision on the submission of revised tax returns (calculations in the form 6-NDFL, settlements on insurance premiums), repayment of debt on personal income tax and insurance premiums, submission of explanations, reasons and circumstances explaining the existence of grounds for an invitation to a commission, is established for the payer in within 10 working days from the date of receipt of the information letter.

After the expiration of the established period, the tax authority draws up a notice of the call of the taxpayer (its form is approved Order of the Federal Tax Service of the Russian Federation dated 08.05.2015 No.MMV-7-2/ [email protected] ) in the following cases:

• in case of non-submission of specified documents;
• in case of non-payment of debt on personal income tax and insurance premiums;
• in case of failure to provide explanations, which provide reasoned reasons explaining the lack of grounds for an invitation to the commission.

Consideration of the activities of organizations and individual entrepreneurs at a meeting of the commission

The activities of a taxpayer, tax agent, payer of insurance premiums at a meeting of the commission are considered on an individual basis. In this case, the representative of the organization (or individual entrepreneur) is invited to:

Give explanations on the revealed facts, inconsistencies;

Clarify the activities carried out (or planned to be carried out) in order to improve the financial and economic performance and prevent violations of the legislation on taxes and fees.

Based on the results of the consideration, the commission formulates recommendations on eliminating violations committed in the formation of the tax base, the basis for calculating insurance premiums, as well as on taking measures aimed at attracting the payer to pay debts on personal income tax, insurance premiums.

For example, it might be suggested:

submit updated calculations in the form 6-NDFL and calculations on insurance premiums for previous tax periods, in which it is necessary to clarify reporting indicators, including the expenses of payers of insurance premiums for paying insurance coverage, amounts not subject to insurance premiums, the amount of additional tariffs for insurance premiums and the amounts of contributions calculated according to these tariffs, the number of employees in whose favor the income is accrued;

• transfer the amount of debt for personal income tax and insurance premiums, taking into account penalties;
• take measures to eliminate negative trends in subsequent reporting periods.

Recommendations should contain a specific deadline for eliminating violations in accounting that led to an underestimation of the tax base for personal income tax, the base for calculating insurance premiums. The recommended period is 10 working days from the date of consideration of the payer's activities at a meeting of the commission.

Based on the results of consideration of the payer's activities at a meeting of the commission, a protocol must be drawn up, which records:

The term for the elimination of violations (distortions) in accounting, which led to an underestimation of the tax base for personal income tax, the base for calculating insurance premiums.

Information based on the results of the work of the “salary” commission can be sent to law enforcement, regulatory and other bodies (for example, to internal affairs bodies, territorial bodies of the FMS, GIT, etc.) for decision-making in accordance with their competence.

If employers pay wages below the subsistence level or the minimum wage, information about such employers is quarterly sent for appropriate action by the tax authorities:

At the territorial level - to local governments;

At the regional level - to the bodies for labor and employment of the constituent entities of the Russian Federation and the State Labor Inspectorate for the constituent entities of the Russian Federation.

What should I do if I receive a notification from the tax office?

According to pp. 4 p. 1 art. 31 Tax Code of the Russian Federation the tax authority has the right to call taxpayers (payers of fees or tax agents) on the basis of a written notice to provide explanations in connection with the payment (withholding and transfer) of taxes and fees by them or in connection with a tax audit, as well as in other cases related to the implementation of their norms Tax Code of the Russian Federation, in particular, within the framework of the meeting of the "salary" commissions.

The notice states:

Detailed description of the purpose of calling the taxpayer (fee payer, tax agent);

Date and time of appearance;

The address of the inspection and the number of the office where you need to come.

The IFTS call notification can be sent in one of the following ways:

Representative of the organization in person against receipt;

By registered mail;

In electronic form by TCS. In this case, it is necessary to send a receipt of receipt of the notification to the IFTS for TCS within six working days ( clause 5.1 of Art. 23 Tax Code of the Russian Federation). If this is not done, the inspectorate may block the bank accounts of the organization ( pp. 2 p. 3 art. 76 Tax Code of the Russian Federation).

The interests of the organization can be represented by its head or representative acting by proxy ( paragraph 1 of Art. 26, paragraph 1 of Art. 27, paragraph 1 of Art. 29 Tax Code of the Russian Federation).

If you do not come to the meeting of the "salary" commission

The non-appearance of a taxpayer, tax agent, payer of insurance premiums shall be recorded in the minutes of the meeting of the commission.

If a taxpayer (tax agent, payer of insurance premiums) does not appear at a meeting of the commission for a good reason, the meeting may be postponed. In this case, a notification is sent again in the form approved by Order of the Federal Tax Service of the Russian Federation No.MMV-7-2/ [email protected] .

In the event that duly notified payers fail to appear for the commission without a valid reason, they are subject to mandatory liability measures provided for Art. 19.4 Administrative Code of the Russian Federation.

According to Part 1 Art. 19.4 Administrative Code of the Russian Federation Disobedience to a lawful order or demand of an official of a body exercising state supervision (control), state financial control, or an official of an organization authorized in accordance with federal laws to exercise state supervision shall entail a warning or the imposition of an administrative fine:

For citizens - in the amount of 500 to 1,000 rubles;

For officials - from 2,000 to 4,000 rubles.

In addition, in relation to payers who did not appear at the meeting of the commission without good reason and whose reporting data do not indicate a positive change in their financial condition, the following measures may be taken:

• repeated call to the interdepartmental commission under local governments;
• a call to the interdepartmental commission under the administrations of the constituent entities of the Russian Federation (in relation to state and municipal unitary enterprises, joint-stock companies with the participation of the capital of the Russian Federation of the corresponding constituent entities of the Russian Federation or municipalities);
• conducting a pre-verification analysis in the prescribed manner;
• preparation of materials for the appointment of an on-site tax audit.

Subsequent monitoring and analysis of taxpayer reporting

Even after the taxpayer has visited the "salary" commission and signed the relevant protocol, the tax authority will monitor its activities. This is due to the need to monitor the implementation of the recommendations prescribed in the protocol. Letter No.ED-4-15/ [email protected] the following types of monitoring are provided.

Quarterly monitoring

It is carried out in the context of personal income tax and insurance premiums: Analysis of the revised tax returns submitted after the meeting of the commission with an increase in tax liabilities and the determination of the amount of personal income tax (insurance contributions) that were additionally received by the budget (fill in the forms given in appendices 10, 11, 15); Control over the repayment of personal income tax debt and insurance premiums (appendices 12, 16); Dynamics of the number and wages (Appendix 13); Dynamics of tax burden indicators (Appendix 7)

Monthly monitoring

Tracks changes in the receipt of personal income tax and insurance premiums to the budget and is carried out in relation to tax agents who have debts in the transfer of personal income tax, and payers of insurance premiums who have debts in the transfer of insurance premiums, paying wages below the average level according to the codes of types of economic activity (Appendices 14, 17 )

If the results of the monitoring do not reveal positive trends and at the same time officials (individual entrepreneurs) do not provide reasonable explanations, the entire package of documents on these taxpayers will be submitted to the pre-audit analysis department to consider the issue of including field tax audits in the plan.

FTS in letter no.ED-4-15/ [email protected] presented an updated procedure for the work of "salary" commissions. One of the features of this document is that its effect will apply to the analysis of data on the accrual and payment of both personal income tax and insurance premiums. The selection of payers whose activities are subject to consideration by the commission is carried out on the basis of lists that are formed by analyzing the available information on the financial and economic activities of payers. Taxpayers who do not appear at this commission without a good reason or do not comply with the recommendations of the tax authorities following the results of the commission's meeting may be held administratively liable. In addition, field tax audits may be initiated against them.

Our clients who are in accounting services receive letters about the insufficient level of wages in the organization compared to the industry average. See an example of such a letter below.

What to do if you receive such a letter and how to respond to it?

The industry average level of wages, should it be so? We suggest referring to the Labor Code of the Russian Federation. We look at article 133.1, from which we understand that the subject of the Russian Federation accepts a regional agreement with its own level of the minimum wage, while this level cannot be lower than the level of wages established by federal law.

In Moscow, the minimum level at the moment is 18,742 rubles according to the Moscow tripartite agreement. It turns out that there is no requirement in the legislation for an industry-average level of wages.

The message of the tax inspectorate about the increase in wages to the industry average level is illegal.

However, such letters of wage increases are aimed at legalizing "shadow" wages. Inspectors believe that wages within the minimum wage or slightly higher in Moscow simply do not correspond to reality. The tax inspectorates are recommending a revision of the salary level and report that otherwise the company may be selected for an on-site tax audit. By the way, if you refer to the current Order of the Federal Tax Service No. MM-3-06 / [email protected] dated 05/30/2007, then, in paragraph 5 of the Order, we will find a condition for the payment of an average monthly salary not lower than the industry average, otherwise, a lower salary will be one of the criteria for conducting an on-site tax audit (paragraph 5 of the Order).

What do we offer our clients? Be sure to respond to the letter of the IFTS by compiling a written response. Attach a copy of the staff list to the answer. State the reason for paying this level of wages.

Answer options could be:

• If wages are not paid in full due to the reduced working hours of some employees - “due to part-time employment in the organization of the following employees, the salary per employee amounted to 20,000 rubles, however, taking into account part-time work, the average salary per employee employee is 40,000 rubles, which is within the industry average.
• If the company's revenue is low - "due to high competition in the market in this industry, the company's revenue is not sufficient to raise wages to the industry average level. The average salary per employee is 20,000 rubles, which is more than the minimum wage in Moscow. During 2018, with a favorable economic situation, it is planned to increase the salaries of employees.”
• If the company has a difficult financial situation - “due to the difficult financial situation of the company and the reduction in revenue and profit indicators, at the moment there is no way to raise employees' wages to the industry average. As financial performance improves, wages will increase.”

We recommend that customers read this letter, make a decision and write a response. If you decide to increase salaries, then be sure to inform in a letter that from the 01st of the month the salaries of employees will be increased to such and such an amount and attach a copy of the new staffing table.

If you need help in preparing a written response, or you want to get an accounting service, contact the specialists of our company

The heads of those companies that pay wages below the average level by type of economic activity, taking into account data on "low-wage" organizations, are invited to the "salary" commission. Moreover, the function of the “salary” commission is not to increase wages for employees of enterprises (there are organizations that regulate labor relations for this), but to bring hidden forms of remuneration out of the shadow (letter of the Federal Tax Service of Russia for Moscow dated August 8, 2007. The legal status of the “salary » commissions The legal status of a «salary» commission is not defined by any regulations. There is no such concept in labor, tax, or civil legislation. As a rule, they operate on the basis of orders from local authorities.

So, in Moscow, such a commission is guided by the order of the Federal Tax Service of Russia for Moscow dated February 22, 2008.

No. 96 and Decree of the Government of Moscow dated May 24, 2006 No. 867-RP "On the Interdepartmental Commission of the Government of Moscow on the interaction of state authorities of the city of Moscow, federal state authorities, enterprises and organizations of the city of Moscow on issues of remuneration, payment of taxes and insurance premiums ". Commissions established in the regions are guided by similar orders. But the main document, which is the fundamental basis for the formation of "salary" commissions, is the recommendations of the Federal Tax Service of Russia, set out in the Basic Provisions for the Implementation of the Letter of the Federal Tax Service of Russia dated May 18, 2007 No.

No. MM-14-02/220dsp@ "On the work of tax authorities with unprofitable organizations", brought by the letter of the Federal Tax Service of Russia dated August 30, 2007 No. SK-14-02/343dsp@.

Despite the unsettled status, you should not ignore the invitation to the "salary" commission. The refusal may be followed by a priority tax audit. Also, the materials of the company can be transferred to the city labor inspectorate or the prefecture.

Here you will find examples of explanations when the salary will be increased at the request of the IFTS or will remain the same. Main page >Sample explanation to the tax. Low wages.

In addition, a fine of 2,000 to 4,000 rubles may be imposed on the head of the company under Article 19.4 of the Code of Administrative Offenses for disobeying the lawful order of an official of the body exercising state supervision (control). Since the right to demand explanations from taxpayers is enshrined in Article 31 of the Tax Code.

It should be noted that the correctness of this approach was also confirmed by court decisions (Decree of the Federal Antimonopoly Service of the Far Eastern District dated November 1, 2007 No. F03-A51 / 07-2 / 4597). On the other hand, since there is no normative regulation of the actions of "salary" commissions at the legislative level, there is no regulation for attending them. Therefore, the manager can visit the commission in the company of relevant specialists: an accountant, lawyer, financier, consultant, etc. Any employee can also represent the company on the basis of a duly executed power of attorney. Wages Regulatory authorities pay close attention to the wages paid by firms to their employees, because wages are the main component of the base for calculating insurance premiums and personal income tax.

If the official wages of employees are below the industry average, then controllers assume that such wages are additionally paid money that is not taken into account in taxation: the so-called payments in "envelopes", "shadow" or "gray" wages. It should be noted that the concept of "average wage level" is used only for statistical data. Neither labor nor tax legislation provides for such a concept.

Labor legislation operates with the concept of "minimum wage". Thus, according to Article 133 of the Labor Code, the monthly salary of an employee who has fully worked out the norm of working hours for this period and fulfilled labor standards (labor duties) cannot be lower than the minimum wage. In addition, a regional agreement on the minimum wage may establish the amount of the minimum wage in a constituent entity of the Russian Federation (art.

131.1 of the Labor Code of the Russian Federation). It can be established for employees working in the territory of the corresponding subject of the Russian Federation, with the exception of employees of organizations financed from the federal budget. Dangerous moment The legal status of the "salary" commission is not defined by any normative acts.

However, the invitation should not be ignored. The refusal may be followed by a priority tax audit. In addition, a fine may be imposed on the head of the company, since the right to demand explanations from taxpayers is enshrined in Article 31 of the Tax Code. The size of the minimum wage in a constituent entity of the Russian Federation is determined taking into account the socio-economic conditions and the subsistence level of the able-bodied population in the corresponding constituent entity of the Russian Federation.

It cannot be lower than the minimum wage established by federal law. Failure to comply with these provisions is a violation of labor legislation, which entails the imposition of a fine in accordance with Article 5.27 of the Code of Administrative Offenses: for officials from 3,000 to 5,000 rubles; for an organization from 30,000 to 50,000 rubles. In addition, violation of labor and labor protection legislation by an official who was previously subjected to administrative punishment for a similar offense entails disqualification for a period of one to three years. Please note that the minimum wage in force in Moscow is (agreement dated December 2, 2010 "On the minimum wage in the city of Moscow for 2011 between the Government of Moscow, Moscow associations of trade unions and Moscow associations of employers"): from 1 January 2011 - 10,400 rubles; from September 1, 2011 - 10,900 rubles. The size of the "average industry" salary Those managers whose average salary in the company is less than the average industry level are invited to the meeting of the "salary" commission.

The definition of “average industry salary”, which inspectors operate, is mentioned in the “Concept for the planning system for field tax audits”, approved by order of the Federal Tax Service of Russia dated May 30, 2007 No. MM-3-06 / [email protected] This order also approved the Public Criteria for Self-Assessment of Risks for Taxpayers, used by the tax authorities in the process of selecting objects for on-site tax audits. One of the criteria is "the payment of the average monthly salary per employee of the average level by type of economic activity in the constituent entity of the Russian Federation." The sources for obtaining information on statistical indicators of the average level of wages by type of economic activity in a city, district or in general for a constituent entity of the Russian Federation are also determined by the above order: official websites of the territorial bodies of the Federal State Statistics Service (Rosstat).

If your employees receive wages below the industry average, the tax authorities may require written explanations. We have given below a sample of explanations to the tax office about the reasons for the low level of wages (below the industry average). What will happen if you do not send explanations to the IFTS about the reasons for low wages? They will assume that you are giving out your salary in envelopes. Moreover, funds will also come for tax authorities with checks: since there is a base for personal income tax, it means that a base for contributions has appeared. Help for an accountant.

Find out the norms of working hours and the postponement of holidays in 2017. Where does the IFTS get information about the average salary in the industry? The living wage is approved by the regional authorities.

You can find it on the Internet in regional news or on the website of the local government. And the industry average wage. Thus, you can already figure out now whether you have a risk of writing explanations for the tax authorities or not. In any case, our sample explanation to the tax office about the reasons for the low level of wages will help you. Explanations to the tax inspectorate about the reasons for the low level of wages (below the industry average) to the Head of the Federal Tax Service of Russia No. 20 for the city of Kuroyedov from Master Manufacturing Company LLC TIN 708123436 KPP 770801001 Address (legal and actual): 125007, Moscow

40 cash register at Nadezhny Design Bureau, c/c BIK 044583222, OGRN 123, Moscow

No. 45/7 that the level of the average monthly salary in our organization per employee is lower than the average monthly salary by type of economic activity.

In connection with the receipt of the above message, we explain that the salary of all employees of LLC “Production Company ‘Master’” is higher than the minimum wage. The average monthly salary per employee in an organization is determined by dividing the payroll for the month by the number of employees. There are employees in Master Production Company LLC who are not full-time, it is their salary that is lower than the industry average.

The salaries of other employees are above the industry average. Attachment: Calculation of the average monthly salary LLC "Production Company 'Master'" Head of the organization A.V. © 1997–2017 Aktion Accounting LLC Magazine Simplified - about the simplified taxation system 8 800 550-15-57 All rights reserved.

Full or partial copying of any materials of the site is possible only with the written permission of the editors of the magazine "Simplified".

Copyright infringement entails liability in accordance with the legislation of the Russian Federation. Registered by the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor). Registration certificate PI No. FS77-62261.

For many years, the tax inspectorate has been unsuccessfully fighting employers who pay wages “in envelopes”. Directors and entrepreneurs are invited to all sorts of commissions, where by requests, and sometimes by threats, they are forced to increase the level of wages reflected in the reports. The purpose of the state, from my point of view, is, of course, not to take care of the workers, but to increase the collection of taxes and replenish the budget. And taking into account the worsening of the general economic situation in our country, the increase in spending on defense and the army, assistance to the Crimea, etc. The pressure on business will only increase. With this, I think few will argue.

In the summer, officials mostly go on vacation. But this does not mean that businessmen could also relax.

I don’t know about you, but in our region in July, many individual entrepreneurs received letters of recommendation on wage increases. Moreover, they even set a deadline - to report before September 1, 2014.

I can assume that after coming out of the summer holidays, as they say "with renewed vigor", the officials will again take up their favorite pastime - holding commissions for the legalization of wages. They will most likely start with the “silent ones” who ignored the letter of recommendation. For this reason, you should not throw away such letters, but you need to convince the tax authorities in writing that you are right. At one time, at the request of a client, I wrote a response to a similar letter. Today I corrected it a little, taking into account the size of the year, and I suggest you familiarize yourself with it. Sometimes when writing an answer you can’t find the right wording, and such a cheat sheet will help you quickly come up with your own legend.

To the head of the MRI No. ___ on ________________________ from IP Ivanova Tatyana Valentinovna, TIN 89 address: ___________________ Explanatory note in response to the letter of recommendation on salary increases I can explain the following: As of January 01, 2014, in labor relations with IP Ivanova T.V. Consists of 14 full-time employees. According to the staffing table, by order of the head, from

The official salaries of the employees amounted to 5,554.00 (Five thousand five hundred and fifty four) rubles. The salary of each employee consists of an official salary in the amount of 5,554.00 rubles, a monthly bonus in the amount of 1,000.00 rubles. And compensatory allowances for work in special climatic conditions in the amount of 15% (983.10 rubles). Thus, the wages of an employee of our enterprise from July 01, 2014 amounted to 7,537.10 rubles.

Wages are paid to employees at least every half a month on the day established by the employment contract. Currently, the company is in a difficult financial and economic situation, which is caused by the following objective reasons: Our company is engaged in the manufacture and sale of fur products.

This type of activity is seasonal, the sale of products occurs mainly in the autumn-winter period, the rest of the time the company is idle. The general warming of the climate, and as a result, a "mild" winter, also led to a decrease in consumer demand for fur products, which negatively affects the company's income. Prices for raw materials, semi-finished products, fuels and lubricants, expenses for advertising and rental of premises for traveling trade, i.е. The overall level of costs of the enterprise during 2014 increased significantly. For the above reasons, the wages of the company's employees were below the industry average. We inform you that during 2014 (tentatively autumn 2014) it is planned to increase the official salaries of employees in the whole enterprise.

The size of the salary increase will depend on the financial situation of the enterprise. IP Ivanova T.V. _____________ M.P.

With this letter we achieve several goals: We do not ignore the tax authority, which is not recommended in this case; Argumentatively explain the reasons for low wages at the enterprise; We nominally agree to increase it, but we do not promise; Thus, we reduce the risks of calling the manager (entrepreneur) for a commission. An acquaintance of the IP also wrote a letter to one of these commissions about the global crisis and the difficulties in our country, and that a provincial employer with 2-3 employees potentially cannot overcome these difficulties (if automobile plants were suspended!).

To which the commission said that they understand everything. But they also have work, and please write simply: “we promise to raise wages to the level of c,” and in the Stavropol Territory they came up with the idea of ​​equating the minimum wage to the subsistence level, and this is not 5554, but 7300 rubles. Now everyone registers employees for 2/3 and 1/4 rates - and the law is observed! And I wrote to them - Limited Liability Company "" TIN / KPP OGRN Index, Russia, city, house street Phone ____________________________________________________________ Ref. Federal Tax Service of Russia for the Perm Territory Federal Tax Service of Russia for the Perm Territory IFTS for the Leninsky District of Perm “Response to Ex. At present, Federal Law No. 82-FZ (hereinafter referred to as Law No. 82-FZ) is in force.3 of this Law, the minimum wage is used to regulate wages, as well as to determine the amount of benefits for temporary disability.

The minimum wage cannot be lower than the subsistence level of the able-bodied population (Art. At present, the minimum wage is equal, from January 1, 2014, to 1 of Law N 82-FZ, as amended.

Federal Law No. 336-FZ). This means that the salary of an employee who has fully worked out the monthly norm of working hours or fulfilled labor standards, taking into account all additional payments, allowances, incentives and compensation payments, cannot be lower than the specified size or the regional minimum wage, if it is established in the constituent entity of the Russian Federation. The minimum wage in a constituent entity of the Russian Federation is established by a regional agreement (part 133.1 of the Labor Code of the Russian Federation) and cannot be lower than the minimum wage approved by federal law (part 133.1 of the Labor Code of the Russian Federation).

133.1 of the Labor Code of the Russian Federation). Market Ultimate Gann Course. However, labor legislation allows the establishment of salaries (tariff rates) as components of the wages of employees less than the minimum wage, provided that their wages, including all elements, will not be less than the minimum wage established by federal law.

Thus, if the total wage (including salary, allowances and compensation) exceeds the minimum wage, then there are no violations. Table for calculating the average salary per employee for 2011.

And subsequent years: Payroll year for the current yearAverage payroll for the year The amount of average wages per 1 person per monthMinimum wage in the country for the current year, taking into account the Ural coefficient 19179 137-495 9729 020-631210 125-296 387-10 Explanation to the table: payroll for the current year / 12 months / number of people = The amount of average wages per 1 person per month. We also divide 2014 into 6 months. Director of OOO «» full name.

Explanations to the bank about the low tax burden. And at the end of the article, they gave an example of compiling explanations to the tax office about the reasons for the low level of wages in 2016. Sample explanation to the tax about low wages. Explanations to the tax office about the reasons for the low level of wages. Below is a sample explanation to the tax on wages for each case.

Sent notification for clarification. Explanation to the tax office on low wages sample Sample version of the explanation to the tax office on low wages. It turns out that the demand for an explanation of the reasons for the low tax burden is not regulated in the Tax Code of the Russian Federation
. An example of an explanation for a low tax burden no one is interested in checking by the tax service, however, if this happened, or you are required to report without a visit due to a low tax burden, then you must correctly explain it and indicate the reasons for such a low level of reasons were given.

In what cases is it necessary to provide an explanation to the tax authorities about the low tax burden on profits. Explanations must be sent, because if everything is in order with the accounting department, then there will be no on-site tax audit. Having received a similar request from the tax authorities to provide an explanation to the tax sample, you can see below, you should answer it. Please help me write an explanatory letter to the tax office for low salary. How to write a collective letter to the boss about salary? In this case, in the explanations about low wages, write from what date the salaries increased. Please help me write an explanation to the tax office, they demand to write why the average monthly salary in the organization is lower than the small consumer budget? How to write explanations to the tax. Explanations to the tax authorities about the reasons for low wages
. A secondary increase in the industry average income indicator and, as a result, tax collection in the region as a whole. Sample explanations to the tax office on the reasons for the low level of wages below the industry average. Explanation in the tax sample about low wages Opel omega b repair instructions for repair, amoxiclav dispersible tablets instructions for use Providing explanations about. A link to a sample Low Wage Explanation is provided below at. How to write an explanation to the tax authorities about the reasons for paying wages below the subsistence level and below. A link to a sample Low Wage Explanation is provided below in the recommendation. Found 5 explanatory in the tax about low salary sample. Explanations to the tax about the reasons for low wages
What will happen if you do not send explanations to the tax office about the reasons for the low. You will find out from this article. Explanations to the tax office about low wages Maybe someone came across, please send a sample letter. Meridian Limited Liability Company more Organization in the income tax return for 2015 Tax and Customs Board innovations in the Fr.

Our clients who are in accounting services receive letters about the insufficient level of wages in the organization compared to the industry average. See an example of such a letter below.

What to do if you receive such a letter and how to respond to it?

The industry average level of wages, should it be so? We suggest referring to the Labor Code of the Russian Federation. We look at article 133.1, from which we understand that the subject of the Russian Federation accepts a regional agreement with its own level of the minimum wage, while this level cannot be lower than the level of wages established by federal law. In Moscow, the minimum level at the moment is 18,742 rubles according to the Moscow tripartite agreement. It turns out that there is no requirement in the legislation for an industry-average level of wages.

The message of the tax inspectorate about the increase in wages to the industry average level is illegal. However, such letters of wage increases are aimed at legalizing "shadow" wages. Inspectors believe that wages within the minimum wage or slightly higher in Moscow simply do not correspond to reality. The tax inspectorates are recommending a revision of the salary level and report that otherwise the company may be selected for an on-site tax audit. By the way, if you refer to the current Order of the Federal Tax Service No. MM-3-06 / [email protected] dated 05/30/2007, then, in paragraph 5 of the Order, we will find a condition for the payment of an average monthly salary not lower than the industry average, otherwise, a lower salary will be one of the criteria for conducting an on-site tax audit(point 5 of the Order).

What do we offer our clients? Be sure to respond to the letter of the IFTS by compiling a written response. Attach a copy of the staff list to the answer. State the reason for paying this level of wages.

Answer options could be:

We recommend that customers read this letter, make a decision and write a response. If you decide to increase salaries, then be sure to inform in a letter that from the 01st of the month the salaries of employees will be increased to such and such an amount and attach a copy of the new staffing table.

We are thoroughly preparing for the commission on wages!

The level of control over the observance of the rights of the personnel of enterprises by the state is becoming higher and higher every day. First of all, under close attention is the level of remuneration, which is checked for compliance with the industry average.

If the indicators do not agree, employers are called to the commission on wages to the tax and administration for clarification. The purpose of the "salary commissions" is the legalization of wages and labor relations between the employer and employees.

Objectives and powers of "salary" commissions on remuneration

In the Russian Federation, there are so-called "salary" commissions, which have the right to verify the legality of the amount of wages paid and accrued to employees. Supervisory powers in this area have different bodies: the tax, the State Labor Inspectorate and local government agencies.

For many years, the Interdepartmental Commission for the Legalization of Wages under the Government of St. Petersburg has been functioning in St. Petersburg, the main task of which is to promote the legalization of labor relations and eliminate wage arrears to the personnel of companies located in the city.

Similar commissions have been formed under the administrations of the districts of St. Petersburg in order to legalize wages and protect the rights of the personnel of enterprises that are located on the territory of a certain district of the northern capital.

These commissions are constantly functioning collegiate bodies, including employees of the district administration. At

The key tasks of the Commission should be to identify information about the payment of wages below the minimum or about delays in payment.

Such cases are analyzed within the framework of the Commission meetings, where representatives of enterprises caught in these violations are invited.

Also, the Commission on Wages is faced with the task of establishing interaction with supervisory authorities in this area (the State Labor Inspectorate, the Prosecutor's Office, internal affairs bodies, tax authorities), as well as statistical bodies and trade unions of workers.

In addition, one of the important activities of the Commission is to address issues of legalizing labor relations.

Every quarter, the Commission holds meetings, and their results can be sent to the control authorities in order to resolve the issue of holding the employer accountable, as well as curbing possible violations in the field of remuneration.

The Commission on Wages is called mainly by the heads of enterprises that pay wages that are lower than established in the region. Often, the average industry salary according to OKVED is also considered as a basis - the average salary level by type of economic activity, which significantly exceeds the minimum wage.

The key task of such meetings is the legalization of shadow wages: an increase in wages for the personnel of enterprises and the withdrawal of “gray” wages from the shadow, since the amount of insurance premiums and personal income tax for each employee directly depends on this.

They call for a salary commission, what to prepare for?

Despite the fact that the Salary Commission is an advisory body, the challenge should not be ignored.

It is important to prepare documentation confirming the fact of accrual and payment of wages not less than the amount established for the industry in the region. The easiest way is to provide a copy of the staffing table.

Going to the “salary” Commission, the manager must be ready to give a clear explanation of the reason for low wages in order to prevent incorrect conclusions about the unreasonability of the accrued salary by members of the salary commission, which are made on the basis of general statistics.

It is important that all answers to the questions of the participants of the Pay Commission be as complete as possible, they must fully confirm the validity of just such wages in the company. It is necessary to exclude even the slightest hint of dishonesty of the organization.

For example, you can indicate the early stage of development of the enterprise or the lack of profit. Temporary difficulties, including changing market needs, reduced sales, reduced funding associated, for example, with the financial crisis, can also be considered as a possible reason for paying low wages.

As a common reason for low wages, part-time employees, or their part-time employment in the organization, are often cited. This guarantees part-time employment and gives staff the opportunity to earn additional income. In addition, a special bonus system can be provided for employees, which depends on the results of work and, for example, sales volume.

The positive moment is that the invitation of employees of the enterprise to the meeting of the commission on the legalization of wages is not provided, they listen only to the "versions" of the leaders.

The results of the commission on the legalization of wages: maintaining the balance of the parties

As a result of the meeting of the salary Commission, the heads of enterprises should receive a proposal to raise the salary of the staff, as well as the employer to report on this later.

In this situation, it is important that the decisions of the Commission on wages are advisory in nature, that is, they do not have to be executed. However, it is highly likely that such a decision may be addressed to a body that has the authority to hold liable both the legal entity and its leaders for violating the requirements of the law.

Since 2015, administrative liability has been provided for violations in the field of labor relations for each employee, and in each individual case it ranges from 30 to 50 thousand rubles for legal entities (for management and individual entrepreneurs from 1 to 5 thousand rubles).

Most often, the commissions for the legalization of wages under the administrations cooperate with the district prosecutor's offices of the city. In addition, government agencies are also recommended to keep records of information from "salary" commissions under district administrations in the event of placing government orders and considering investment proposals in the field of real estate.

Experts also recommend implementing the decisions of the Commission on wages step by step, gradually increasing the level of remuneration of specialists, since as a result the burden of paying mandatory payments and taxes will increase. In addition, this will help eliminate suspicions of dishonesty of the enterprise and understand what salaries for employees are available to a legal entity in the current economic conditions.

What should I do to avoid being called to the payroll?

If you know for sure that the average salary of specialists in your industry according to OKVED is significantly higher than what you pay at your enterprise, you should not wait for an invitation to the salary commission to give explanations, because in this way you can fall under the close attention of government agencies.

However, you can easily maintain the required salary level of your employees by using the personnel outstaffing service. At the same time, you will not only be able to protect yourself and your company from payroll commissions and audits by the tax, prosecutor's office and other government agencies, but also significantly reduce your personnel costs.

In addition, you additionally receive personnel records, migration documents and a tax deduction.

ZaStatom specialists will tell you more about all the benefits of outstaffing. Request a calculation of benefits (in rubles for each employee) right now - just call our office.

04.12.2015