Extension of deadlines for payment of insurance contributions

The Government of the Russian Federation has decided to extend the deadlines for paying insurance contributions for Q2-Q3 of 2022 by a year.

The relevant Government Decree dated April 29, 2022 No. 776 has been signed.

The rescheduling will be carried out proactively, payers will not have to submit any applications.

The deadline for payment of contributions is extended by 12 months.

Insurance contributions need to be paid in 2023, together with contributions for the corresponding periods of 2023, and this needs to be included in the budget.

In accordance with clause 2 of Art. 431 of the Tax Code of the Russian Federation, contributions must be paid monthly no later than the 15th day. Thus, payments on deferred contributions must be made on the following dates:

• for April 2022 - no later than May 15, 2023;
• for May 2022 - no later than June 15, 2023;
• for June 2022 - no later than July 17, 2023 (because July 15, 2023 falls on a Saturday);
• for July 2022 - no later than August 15, 2023;
• for August 2022 - no later than September 15, 2023;
• for September 2022 - no later than October 16, 2023 (since October 15, 2023 falls on a Sunday).

There is one criterion for applying a deferment for the payment of insurance contributions in 2022 - this is the main OKVED code, information about which is contained in the Unified State Register of Legal Entities / Unified State Register of Individual Entrepreneurs as of April 1, 2022.

It is important that it be included in the lists from the Government Decree of April 29, 2022 No. 776.

The Decree of the Government highlighted 3 Annexes with the Lists of OKVED:

Annex No. 1 contains a list of OKVED codes, according to which it is possible to postpone the payment of insurance contributions for Q2 2022 by 12 months.

If the main OKVED code of the organization and individual entrepreneur applying for the privilege matches the code from the list, they can take advantage of the deferment in respect of insurance contributions calculated:

• from payments and other remuneration in favour of individuals for April-June 2022;
• for 2021 from the income of an individual entrepreneur excessing 300,000 rubles.

Thus, the deferment of payments on contributions for Q2 2022 will be received by companies carrying out more than 70 types of activities. In particular, these are those who are engaged in the production of food, clothing, furniture, textiles.

Annex No. 2 contains a list of OKVED codes, according to which it is possible to postpone the payment of insurance contributions for Q3 2022 by 12 months – contributions calculated from payments and other remuneration in favour of employees for July - September 2022.

The deferred payment of insurance contributions for Q3 2022 will refer to organizations that carry out more than 30 types of activities, namely those who produce medicines, are engaged in agriculture, construction, etc.

Important: the extension of the deadlines for paying insurance contributions does not apply to organizations that, as of April 1, 2022, have the organizational and legal form from Appendix No. 3 of the Decree. For example, unitary enterprises, state-owned companies, municipal unitary enterprises, etc.

Annex No. 3 indicates the organizational and legal forms of budgetary organizations for which deferred payments are not provided.

If the company has several types of activities or activities are carried out not according to the main OKVED, regarding the possibility of deferring the payment of insurance contributions, we recommend that you contact the Federal Tax Service at the place of registration for clarification.

When making a decision to postpone the payment of contributions, Unicon specialists must be informed no later than 3 working days before the date of payment of the relevant contributions.

As part of additional services, we can assist in determining the company's compliance with the criteria for the Government Decree. The cost of work will be:

• 2,500 rubles (without request to the Federal Tax Service),
• 5,000 rubles (with sending a request to the Federal Tax Service).