Form of the tax return for the year. Declaration of payment for negative impact on the environment (nvc): how to fill in without errors. How to determine if an object belongs to category iv

Who must submit the declaration in 2017

The payment for environmental pollution, in turn, must be paid to the budget by all organizations and individual entrepreneurs using objects that have a negative impact on the environment in their activities. In this case, the tax regime (STS, OSNO or UTII) does not matter (Art. 23 of the Federal Law of 24.06.1998 No. 89-FZ, Art. 28 of the Federal Law of 04.05.1999 No. 96-FZ). Moreover, it does not matter on what law the organization or individual entrepreneur use the object of negative impact (whether the object is owned or leased).

Objects of negative impact: what they are

At the same time, organizations and individual entrepreneurs are not obliged to transfer payments for environmental pollution if they operate only at facilities of the IV category of hazard (paragraph 1 of Article 16.1 of the Law of 10.01.2002 No. 7-FZ). These are objects on which:

• there are stationary sources of emissions of pollutants, but the amount of emissions into the environment does not exceed 10 tons per year;
• there are no releases of radioactive substances;
• there are no discharges of pollutants that are formed when using water for industrial needs, into the sewage system and into the environment (into surface and underground water bodies, onto the earth's surface).

Advice

Check whether the facilities operated by the organization or individual entrepreneur correspond to IV hazard category. Rosprirodnadzor assigns hazard categories when registering objects in the state register. Accordingly, you can contact the Rosprirodnadzor department and find out the class of your facility (if you previously entered it into the register). If it turns out that you have IV category, then you do not need to pay a fee and, of course, submit a declaration of payment for negative impact on the environment for 2016.

Also on the Rosprirodnadzor website in the "Inspections" section you can find a list of objects of negative impact. There you can download a table in Excel format, which, broken down by constituent entities of the Russian Federation, contains, among other things, the names of the organization (IE) and the object belonging to it that has a negative impact on the environment.

Payment deadline for 2016

Who is required to make advances

New declaration form for 2016 and due date

It should be noted that with the approval of the form new declaration According to NVOS, a rather strange situation occurred in 2017. The fact is that the new declaration form and the procedure for its submission were registered by the Ministry of Justice of Russia only on February 22, 2017, No. 45747. Officially, these documents were also published on February 22. 2017 on the official resource for the publication of regulations. Consequently, these documents officially enter into force 10 days from the date of publication. That is, from March 4, 2017.

It turns out that only from March 4, 2017, organizations and individual entrepreneurs have the right to use the new form. Until this date, the declaration, in fact, cannot be applied. Moreover, before March 4, 2017, Rosprirodnadzor, in our opinion, has no legal basis for adopting a declaration in a form that has not yet officially entered into force.

At the same time, 4 and 5 March 2017 are Saturday and Sunday. March 8 is a festive International Women's Day. Most businesses are not working these days. Also, the divisions of Rosprirodnadzor do not work in these areas. It turns out that only 4 working days are allotted to business in 2017 for the formation and submission of the declaration: March 6, 7, 9 and 10. Moreover, March 7 is a shortened working day.

How and where to submit an electronic declaration?

As for the transfer of the generated file to the bodies of Rosprirodnadzor, then, according to general rule, you need to send the declaration for 2016 via the Internet using the "Personal Account" cabinet on the Rosprirodnadzor website. To prepare and submit the 2016 NIE declaration, the following will be required:

Install the module and fill out the declaration

You can form a declaration for 2016 using the resource user module version 3.8. This module is posted on the Rosprirodnadzor website on February 22, 2017 and takes into account the new declaration form approved by the Order of the Ministry of Natural Resources dated January 09, 2017 No. 3. reported on the Rosprirodnadzor website.

In the section Resource User Reporting, you can click on the "Resource User Module" and download a program for filling out the declaration for free.

Enter the personal account of the organization or individual entrepreneur

On the Rosprirodznazor website, you will need to enter the personal account of the nature user for the preparation and submission of reports to Rosprirodnadzor. You can enter it at https://lk.fsrpn.ru. You can enter, in particular, by login and password used on the State Services portal. Also, at the specified address, instructions are provided on what is needed to access the office and generate reports. Check it out if you have not used your personal account before.

Have a digital signature

You can submit the declaration through your personal account on the Rosprirodnadzor website only with the attachment of an electronic digital signature issued by an accredited center. With this signature, you will need to sign the file with the declaration and transfer it to Rosprirodnadzor. If you do not have an EDS, you will not be able to report electronically.

When can you report "on paper"

• the annual fee for negative impact in 2016 was less than RUB 25,000;
• there is no technical possibility of connecting to the Internet;
• no electronic digital signature.

If there are several objects?

You can find out the contact details of the Rosprirodnadzor unit for submitting the declaration "on paper" on this page. Select the subject you are interested in from the drop-down list and click the required Department of Rosprirodnadzor.

Composition of the new declaration

• title page of the declaration (includes general information about the company or individual entrepreneur);
• calculation of the amount of payment to be paid to the budget (indicating the BCC);
• Section 1. Calculation of the amount of payment for emissions of pollutants into the atmospheric air by stationary objects;
• Section 1.1. Calculation of the amount of payment for emissions of pollutants generated during flaring and (or) dispersion of associated petroleum gas when the volume corresponding to the maximum permissible value of the flaring indicator is not exceeded;
• Section 1.2. Calculation of the amount of payment for emissions of pollutants generated by and burning in flares and (or) dispersion of associated petroleum gas when the volume is exceeded, corresponding to the maximum permissible value of the flaring indicator;
• Section 2. Calculation of the amount of payment for discharges of pollutants into water bodies;
• Section 3. Calculation of the amount of payment for the disposal of production and consumption waste;
• Section 3.1. Calculation of the amount of payment for the disposal of municipal solid waste.

Filling in the declaration: sample

• persons obliged to make payments for the nagative and submit a declaration must include in it only those sections for which they have such an obligation;
• all numerical indicators, except for TIN and KPP, are indicated by filling in the cells, starting from the smallest digit of the number, from right to left, in empty cells zeros are not indicated;
• the amount of the fee is indicated in rubles with an accuracy of one hundredth. Rounding is performed according to the mathematical rounding order.

Title page

• organizational and legal form;
• the name of the organization or the full name of the entrepreneur;
• phone;
• TIN and KPP;
• Full name and signatures of the head and chief accountant.

Calculation of the amount of fees to be paid to the budget

On line 010, the code of the corresponding municipality is indicated - OKTMO according to "OK 033-2013" approved by Order K of the State Standard of Russia dated June 14, 2013 No. OK 033-2013, 159-ST.

Line 020 - in it you need to summarize the totals for the amount of payments, without taking into account the adjustment of their size. The indicator of this line must be formed as the sum of payments for all types of NVOS and include payments calculated:

• within the limits of permissible emission standards (NDV),
• permissible discharge standards (VAT),
• limits on emissions of pollutants and limits on discharges of pollutants exceeding such standards, limits, emissions and discharges (including emergency),
• within the limits for the placement of production and consumption waste and in excess of the specified limits.

• p. 021 \u003d p. 040;
• p. 022 \u003d p. 060;
• p. 023 \u003d p. 080;
• page 024 \u003d page 100.

Line 040 shall reflect the amount of payment for emissions of pollutants into the atmospheric air by stationary facilities, calculated for each stationary source, without adjusting its amount.

The amount for line 040 in the table is determined in the following order: line 040 \u003d line 041 + line 042 + line 043.

Indicator line 040 \u003d total for column 17 of Section 1, line “Total for stationary sources”.
The indicators of lines 041, 042 and 043 are deciphering to the amount reflected in line 040. All the data for filling them out is contained in Section 1.

Line 041 reflects the amount of payment for emissions within the MPE, the amount must correspond to the total for column 14 of Section 1, line “Total for stationary sources”.
Line 042 reflects the amount of payments for emissions within the limits for pollutant emissions (EEC), the amount must correspond to the total in column 15 of Section 1, line "Total for stationary sources".

Line 043 shall reflect the amount of payments for emissions in excess of the emission limit, the amount must correspond to the total in column 16 of Section 1, in the line “Total for stationary sources”.

Other calculation lines are filled in the same way. Each indicator should correspond to the totals of calculations for the corresponding section.

Lines 060 to 063 reflect the amounts of payments for emissions of pollutants during flaring and / or dispersion of associated petroleum gas, calculated for all stationary sources (flare units, dispersion units). This is how a sample of calculating the amount of the fee may look like, in which the KBK are indicated:

Section 1. Calculation of payment for air emissions

• number, date of issue and validity of the permit for the emission of pollutants into the air.

Section 1.1

If the above incineration was not carried out, then it is not necessary to fill in this section and include it in the declaration for 2016.

Section 1.2

Section 2. Calculation of fees for discharges into water bodies

• category of an object that has a negative impact on the environment;
• the name of the facility that has a negative impact on the environment;
• code of an object that has a negative impact on the environment;
• the address of the location of the facility that has a negative impact on the environment;
• number, date of issue and validity of the permit for the discharge of pollutants into the environment.

Section 3: payment for the disposal of production and consumption waste (waste)

• category of an object that has a negative impact on the environment;
• the name of the facility that has a negative impact on the environment;
• code of an object that has a negative impact on the environment;
• the address of the location of the facility that has a negative impact on the environment;
• information on the category of the facility (not filled in if the negative impact (waste disposal facility) does not belong to the person obliged to pay);
• details of the document on approval of standards for waste generation and limits for their placement (date of issue, number, validity period, issued by whom);
• for small and medium-sized businesses, the characteristics of the submitted for reporting period reporting on the generation, use, disposal and disposal of waste (sent by mail / in electronic form), as well as the details of this reporting:
• when sent by post, the date of dispatch and the name of the recipient ( territorial body Federal Service for Supervision of Natural Resources, executive body of the subject Russian Federation);
• in the case of sending in electronic form (date, number assigned on the web portal for receiving reports of the Federal Service for Supervision of Natural Resource Use, or the date and number assigned on the web portals for receiving reports from the executive authorities of the constituent entities of the Russian Federation, and also the recipient of the reporting (territorial body of the Federal Service for Supervision of Natural Resources Management, executive authority of the constituent entity of the Russian Federation);
• the address of the location of the waste disposal facility;

Section 3.1: payment for disposal of municipal solid waste

• category of an object that has a negative impact on the environment;
• the name of the facility that has a negative impact on the environment;
• code of an object that has a negative impact on the environment;
• the address of the location of the facility that has a negative impact on the environment;
• information on the category of the object (not filled in if the waste disposal object does not belong to the person obliged to pay the fee);
• name of the waste disposal facility;
• registration number (if assigned) of the waste disposal facility;
• the address of the location of the waste disposal facility.
• characteristics of the waste disposal facility (included / not included in the state register of waste disposal facilities; does not have a negative impact on the environment).

A responsibility

• for officials (for example, for a director or chief accountant) - from 3000 to 6000 rubles;
• for individual entrepreneurs - from 3000 to 6000 rubles (they are fined as officials)
• for legal entities - from 20,000 to 80,000 rubles.

Let us consider the frequency with which nature users need to report to Rosprirodnadzor and when it is necessary to submit reports: NVOS, 2-TP (waste), 2-TP (reclamation) and SME. And also, what is general categorization.

Let us consider the frequency with which nature users need to report to Rosprirodnadzor and when it is necessary to submit reports: NVOS, 2-TP (Waste), SMEs and environmental fee.

NVOS

Since 2016, the declaration on payment for negative impact on the environment is an annual form of reporting, which must be submitted by March 10 of the year following the reporting year. Thus, for 2018 you will need to report until March 10, 2019.

This declaration must be submitted to all users of natural resources, except for those who operate exclusively at facilities of category IV. The declaration is handed over to the territorial office of the RPN.

Introduction of payment for NVOS to the budget in 2019

Since 2016, business entities must make payments to the budget by March 1 of the year following the reporting year. That is, for 2018, the payment must be made before March 1, 2019.

At the same time, advance payments are not provided for small and medium-sized businesses during the year. Those who do not belong to small and medium-sized enterprises make quarterly advance payments (except for the fourth quarter) no later than the 20th day of the month following the last month of the corresponding quarter of the current reporting period, in the amount of one fourth of the amount paid for the NVOS for last year... And until March 1 of the year following the reporting year, the remaining amount of the payment is made as the difference between the accrued amount and the amount of advance payments made. If, based on the results of the calculation, an overpayment is revealed, then a mechanism is provided for returning the overpaid amount or offset against future payments.

Thus, in 2019 you need to make payments:

• for the first quarter of 2019 - until 04/20/2019;
• for the second quarter of 2019 - until 20.07.2019;
• for the third quarter of 2019 - until 20.10.2019.

Regulations:

1. "On environmental protection": determines that it is necessary to pay for negative impact on the environment, and establishes the types of negative impact.
2. Order of the Ministry of Natural Resources of the Russian Federation of 09.01.2017 No. 3 “On Approval of the Procedure for Submitting a Declaration on Fee for Negative Impact on the Environment and Its Forms”: defines the procedure, terms and form for submitting a declaration on fees for NVOS.
3. Decree of the Government of the Russian Federation of 13.09.2016 No. 913 "On the rates of charges for negative impact on the environment and additional coefficients": determines the rates of charges for each pollutant for 2016-2018. In 2019, the rates established for 2018 are applied, using, in addition to other coefficients, a coefficient of 1.04 (according to the Decree of the Government of the Russian Federation No. 758 dated June 29, 2018).
4. Resolution of the Government of the Russian Federation of 08.11.2012 No. 1148 "On the specifics of calculating fees for negative impact on the environment in the event of emissions into the atmospheric air of pollutants generated during flaring and (or) dispersion of associated petroleum gas".

2-TP (air)

Since 2019, the 2-TP (air) annual report has been submitted to Rosprirodnadzor (previously the report was submitted to Rosstat). The deadline for completion is January 22 of the year following the reporting year. Place of delivery - the territorial office of the RPN.

2-TP (air) is handed over by legal entities and individual entrepreneurs that have stationary sources of emissions of pollutants into the atmospheric air (including boiler houses), regardless of whether they are equipped with treatment plants or not.

Difference from the order of submission of the previous form:

• In the report, sections are filled in separately for each object of negative impact (for each production site);
• If a legal entity or individual entrepreneur has several objects of negative impact and they are located on the territory of different constituent entities of the Russian Federation, then a report in the form is submitted separately for each constituent entity of the Russian Federation to the corresponding territorial bodies of Rosprirodnadzor at the place of registration of the object of negative impact.

2-TP (Waste)

The annual report 2-TP (Waste) shall be submitted by February 1 of the year following the reporting year to the territorial office of the RPN by all economic entities that operate in the field of waste management.

Form 2-TP (Waste) was approved by the Order of the Federal State Statistics Service of 08/10/2017 No. 529 and is officially called "Information on the formation, processing, disposal, disposal, transportation and disposal of industrial waste."

2-TP (reclamation)

The annual report 2-TP (reclamation) is handed over before February 1 of the year following the reporting year to the territorial office of the RPN legal entities and individual entrepreneurs conducting the following activities:

• developing deposits of minerals (including widespread minerals);
• carrying out construction, reclamation, logging, survey work;
• carrying out the placement of industrial, construction and solid household waste.

Form 2-TP (reclamation) was approved by the Order of Rosstat dated December 29, 2012 No. 676 and is officially called "Information on land reclamation, removal and use of the fertile soil layer."

SMEs

The annual form of SMEs is handed over by small and medium-sized businesses. Its official name: "Information on the generation, use, disposal and disposal of waste (except for statistical reporting)".

SMEs are submitted to different regulatory authorities depending on the level of supervision of the facility. For objects of the federal level of control, they report to the territorial body of the RPN, for objects of the regional level of control - to the executive authorities of the subject (for example, the Ministry of Natural Resources of the Sverdlovsk Region).

For objects of the federal level, the reporting procedure is established by Order of the Ministry of Natural Resources of the Russian Federation dated February 16, 2010 No. 30 (as amended on December 9, 2010), the reporting form has been approved. The deadline is set - until January 15 of the year following the reporting year.

For objects of the regional level of control, the form and procedure for reporting can be similar to those established for objects of the federal level, or they can be approved in separate legal acts of the regional level. In this case, the deadline may be different from January 15 of the year following the reporting year.

Environmental fee

Producers and importers of goods and packaging included in the list approved by Order of the Government of the Russian Federation dated 28.12.2017 No. 2970-R “On approval of the list finished goods, including packaging to be recycled after they have lost their consumer properties ”. This list includes 45 groups of goods and nine types of packaging.

You also need to take into account: if a manufacturer uses packaging for his products that falls under the reporting on eco-collection, then he pays the eco-tax (Government Decree of 08.10.2015 No. 1073 as amended on 23.08.2018). For example, a company made paper bags and sold them to a mini bakery, which puts their own cakes in the bags for sale. In this case, the confectionery must pay the eco-tax.

Another point: if the goods were imported in packaging that qualifies for eco-collection, but the goods themselves are not, then the packaging will have to be disposed of or pay eco-collection. For example, a company imported tulips in cardboard boxes - the boxes have to be reported.

Eco-collection forms are annual. Producers report to the territorial office of the RPN, importers - to the Central Office of the RPN. Organizations that are both manufacturers and importers - to the RPN Central Office.

Within the framework of reporting on eco-collection, only the number of goods and packaging released into circulation is taken into account: not the total amount of manufactured / imported goods, but namely those sold to the end consumer.

The procedure for levying environmental fees was approved by the Decree of the Government of the Russian Federation dated 08.10.2015 No. 1073 "On the procedure for collecting environmental fees" (as amended on 23.08.2018). This procedure also spelled out responsibility for non-payment of the environmental fee. Please note that from the reporting for 2018, the period for voluntary payment of the environmental fee after receiving the request from the RPN has been reduced from 30 to 15 calendar days.

There are four types of eco-collection reports, and the first three require a strict submission sequence. If you violate it, the RPN may not accept reports.

1. Declaration on the number of goods released into circulation on the territory of the Russian Federation, packaging of goods included in the list of goods, packaging of goods subject to disposal after they have lost their consumer properties, sold for domestic consumption on the territory of the Russian Federation.

Submitted before April 1 of the year following the reporting year, the form is approved by the Decree of the Government of the Russian Federation of December 24, 2015 No. 1417 (as amended of July 25, 2018) “On the approval of the Regulation on declaring by manufacturers of goods, importers of goods, the amount of goods released into circulation in the territory of the Russian Federation packaging of goods included in the list of goods, packaging of goods to be disposed of after they have lost their consumer properties ”.

2. Report on the implementation of recycling standards.

Submitted before April 1 of the year following the reporting year. The report form was approved by the Decree of the Government of the Russian Federation of 08.12.2015 No. 1342 "On approval of the Rules for the presentation by manufacturers and importers of goods to be disposed of after they have lost their consumer properties, reporting on the fulfillment of waste disposal standards from the use of such goods." For reporting for 2018, the form will be changed, at the moment the bill is under discussion.

Disposal standards are approved by the Order of the Government of the Russian Federation of December 28, 2017 No. 2970-R "On approval of the list of finished goods, including packaging, to be recycled after they lose their consumer properties."

3. Calculation of the amount of environmental tax. The calculation form was approved by the Order of Rosprirodnadzor dated August 22, 2016 No. 488 "On approval of the form for calculating the amount of environmental fee". Submitted before April 15 of the year following the reporting year. Fee rates for 2018 have not yet been approved, the corresponding bill is under discussion.

4. Report on the facilities (capacities) of the main technological equipment to ensure the disposal of waste from the use of goods.

Important: this report should be submitted only to those organizations that have the indicated capacities on their balance sheets!

Completion date: by April 1 of the year following the reporting year. The report form was approved by the Decree of the Government of the Russian Federation of December 30, 2015 No. 1520 "On the unified state information system for accounting for waste from the use of goods" (Appendices 10, 11). The report is divided into two forms:

• information on facilities (capacities) of the main technological equipment to ensure the disposal of waste from the use of goods;
• information about the places of collection of waste from the use of goods, organized by manufacturers, importers of goods.

Frequently Asked Questions on the IEE Declaration of Fees

On February 16, 2017, a new version of the Eco-Expert program was released, which implements the annual Declaration on the calculation of fees for negative impact on the environment (NVOS), developed in accordance with the Order of the Ministry of Natural Resources dated 09.01.2017 No. 3.

This article summarizes the questions that arise in the preparation of the annual Declaration on the fee for the IEE.

We calculated the amount of payment according to the Declaration, it turned out to be less than the amount according to quarterly calculations, why?

Starting from 2016, payers of fees for NVOS, except for small and medium-sized businesses, are required to make advance payments in the I-III quarters. The amount of the advance payment is equal to one fourth of the amount paid for the previous year. At the same time, many nature users continued to make quarterly calculations in accordance with Order No. 204 to determine the advance payment.

As a result, when they begin to compare the amounts of advance payments with the amounts calculated according to the annual declaration, almost everyone gets an overpayment, to the extent that advance payment two quarters more than the annual payment. And this is true, there is no mistake about it.

The fact is that on September 23, 2016, Resolution of the Government of the Russian Federation No. 913 "On rates of payment for NVOS" came into force, which canceled Resolution No. 344, and although the rates of Resolution No. 913 correspond to the rates of Resolution No. 344 (taking into account inflation), the procedure has changed. calculating the amount of the fee. Thus, a number of increasing coefficients were canceled, such as the coefficient of environmental significance, coefficient 2 (for resort areas and the extreme north), coefficient 1.2 (NVOS within the city). In addition, by Order of the Ministry of Natural Resources No. 3, a number of incentive decreasing coefficients were introduced. All this leads to a significant reduction in the amount of fees for the NVOS.

A detailed analysis of the current situation in figures based on the data of a real project was carried out in the article "Calculation of payments for pollution of environmental components: what has changed?" (Journal of the Ecologist's Handbook, No. 2, 2017). Here are the conclusions reached by the authors of this article: "... the amount of payment for 2016 will decrease for various types of impact on environmental components by about 40-70%, and for 2017 - by 30-70%."

Who is obliged to submit the Declaration and pay for the IEE?

The declaration is handed over by the payers of the fee for the NVOS. If your organization, in accordance with Federal Law No. 7-FZ, is not obliged to pay a fee for NVOS, then you do not need to submit the Declaration on payment for NVOS.

And yet who is obliged to pay for the NVOS? At the moment, we can say with confidence that the payers are legal entities and individual entrepreneurs who carry out economic activities at objects of categories I - III, and that objects of category IV are exempted from the fee for NVOS. At the same time, economic entities are exempted from payment for the disposal of solid municipal waste (MSW), the payment for which is paid by regional operators for MSW management. In addition, there is an opportunity for a number of waste disposal facilities (ODP) to receive the Decision of the territorial authority

Rosprirodnadzor on the elimination of negative impact on the environment, allowing to reduce the amount of payment for the organization as a whole.

It would seem that they went through the registration procedure for NVOS objects, received a category and then everything, as in Federal Law No. 7-FZ, but not everything is so simple. Rosprirodnadzor has repeatedly clarified that the calculation of fees for the NVOS is not directly related to the definition of the object providing the NVOS, i.e. with registration of objects of NVOS. Therefore, it is not yet clear how to proceed to objects that were refused registration as not providing NVOS. The situation is aggravated by the fact that in 2016 there were no regional operators for MSW handling. Federal Law No. 486-FZ of 28.12.2016 "On Amendments to Certain Legislative Acts of the Russian Federation" established a transitional period until 01.01.2019 on the introduction utilities on MSW management and establishment of a single tariff on the territory of the RF subjects. Thus, until the day of the approval of the uniform tariff and the signing of agreements of the constituent entities of the Russian Federation with regional MSW operators, the payment for the placement of MSW is carried out by economic entities, as a result of which solid municipal waste is generated.

What do we have as a result? With a high degree of probability, it can be argued that in 2017, all business entities must pay for the NVOS for 2016, regardless of the registration of NVOS objects and the categories assigned to them. An exception may be small offices, in which the lease agreement clearly states that the payment for garbage collection is carried out by the lessor, who has concluded contracts for garbage collection and is the payer of the fee for waste disposal.

Clarification. Rosprirodnadzor in a letter dated February 21, 2017 No. AS-06-02-36 / 3591 "Who pays the fee for the NWOS when placing MSW" expressed its position on MSW, which is as follows: economic entities that actually carry out licensed activities for MSW management, correspond the status of operators for MSW handling, therefore, for 2016 and until the selection in the constituent entities of the Russian Federation of a regional operator for handling MSW with a single tariff, in accordance with the legislation mSW fee is charged from MSW handling operatorscarrying out specialized activities for the disposal of municipal solid waste.

Declaration Form?

On February 22, 2017, the Order of the Ministry of Natural Resources of 09.01.2017 No. 3 "On Approval of the Procedure for Submitting a Declaration on Payment for Negative Environmental Impact and Its Forms" was registered with the Ministry of Justice and published, i.e. entered into force.

The fee for the NVOS must be paid no later than March 1... Therefore, for those who did not use the unpublished Procedure for calculating the amount of the fee, there are three days left (including holidays) to calculate and pay the NVOS fee. Starting from 2017, for untimely and incomplete payment of fees for the IEE is charged penalty of 1/300 key rate Bank of Russia.

Fees are paid separately for four environmental components: emission fees, APG emissions fees, discharge fees and waste disposal fees. Each in its own BCC (budget classification code). It should be borne in mind that if advance payments were made and, for example, an overpayment was formed for waste, then it cannot be automatically included in the payment for emissions, because these components are paid for according to different CBC. The calculated total amounts of the payment for the reporting period (lines 151 - 154 of the Declaration) are subject to payment, the amount of the fee for the refund and / or offset (lines 161 - 164) should not affect the amount of the current payment.

Order of the Ministry of Natural Resources No. 3 determines the form of the Declaration itself, which must be submitted no later than March 10... An Excel formatted Declaration Form can be downloaded from our website.

Attention! In line 010 on the sheet "Calculation of the amount of payment" of the Declaration, the code of the municipality (OKTMO) is indicated on the territory of which the stationary source is located or waste disposal facility (ODP) of production and consumption, it should not be confused with a waste object. In the Declaration form, line 010 contains 11 characters for entering OKTMO, but you only need to specify the first 8 characters of OKTMO, write zeros in the 10th and 11th positions.

What is the procedure for submitting the Declaration to Rosprirodnadzor?

When the stationary facilities of the NVOS and / or OWO are located on the territory of different subjects of the Russian Federation, for each constituent entity of the Russian Federation, you must submit a separate Declaration.

When on the territory of one subject of the Russian Federation is located several objects of the NVOS and / or ORO, you need to submit one general Declaration.

Declaration can be submitted separately for a separate subdivisionlocated outside the location of the organization itself. Consider two main types separate divisions: brancheswhich are vested with all the rights and obligations of a legal entity at the place of registration of such a unit, and representationsthat represent the interests of a legal entity in a certain territory and protect them (rights and obligations remain with the organization itself). The legal status of such units varies. Branches have the right on behalf of a legal entity on the basis of a power of attorney pay a fee for NVOS. Representatives of such a right are deprived.

The following documents must be attached to the Declaration of Fees for the IEE:

• a document confirming the authority of the person obliged to pay a fee to act on his behalf, if the Declaration of payment is submitted by an authorized representative;
• documents confirming the costs of environmental protection measures taken into account in adjusting the size of the fee, if such an adjustment is reflected in the Declaration for the reporting year.

The declaration can be submitted on paper or in the form of an electronic document signed with a digital signature. When submitting an electronic document, the compliance of the data of the owner of the qualification certificate with the data of the person authorized to confirm the accuracy and completeness of the information is checked. In other words, the TIN and other information in the digital signature must match the data specified in the Declaration.

If there is no technical ability to connect to the Internet or there is no digital signature, the Declaration can be submitted in paper form by the person obliged to pay the fee, in person, or through an authorized representative, or by registered mail with a description of the attachment and acknowledgment of receipt.

With an annual fee not exceeding 25 thousand rubles. the payer has the right to submit the Declaration on paper in one copy with the obligatory provision of a copy on electronic medium.

Starting from 01.01.2017, the Rosprirodnadzor portal pnv-rpn.ru has stopped accepting reports, it will be available only for viewing previously submitted reports by 30.06.2017. Now, to receive reports, the State Services portal is used, located at lk.fsrpn.ru. To send reports, you need to have an account on the State Services portal. This must be taken care of in advance, because the registration procedure will take some time to collect the documents required for registration.

Can't find pollutant fee rates

The new payment rates were approved by Resolution No. 913, which brings the rates in line with the Order of the Government of the Russian Federation dated June 08, 2015 No. 1316-r "On approval of the list of pollutants in respect of which measures of state regulation in the field of the environment are applied."

The currently available permits for emissions and discharges were issued without taking into account the Order No. 1316-r, which significantly reduces the list of pollutants and, as a result, the rate of payment for them. For emissions and discharges of pollutants for which there are no payment rates, starting from 2016 you do not need to pay, even if these pollutants are specified in the permits.

The established practice of using fee rates for pollutants with similar characteristics, is unlawful... So in the Letter of Rosprirodnadzor dated January 16, 2017 N AS-03-01-31 / 502 "On consideration of treatment" it was said that "... substances such as abrasive dust, carbon (soot), iron oxide, by their physical properties , relating to particulate matter, it is advisable to take into account in the composition of emissions as suspended solids ”. This and the requirements for payment for pollutants, which were previously applied by the administrators of fees for NVOS, which are absent in Resolution No. 344, are recognized by the courts as illegal. As an example, we can cite the decision of the Arbitration Court of the Khanty-Mansiysk Autonomous Okrug dated January 31, 2014 in case No. A75-2131 / 2013.

Where to get MPE and VAT by sources of emissions and discharges?

The new form of the annual Declaration provides for calculations of pollutants in the context of emission sources and wastewater discharges. This significantly increases the amount of work involved in calculating the fee. In addition, we needed MPE, VEV and VAT, VSS of pollutants for each source and release separately. The permits approve the data on the object as a whole. To get data in the context of sources and releases, you need to raise the project documentation, namely the section of regulation.

How to calculate relief to relief?

They still ask how the relief to the relief is calculated. The payment for the so-called storm drain was canceled back in 2014 (or rather, it was never approved and its application was illegal). Wastewater discharge is regulated by legal acts that determine the relationship between subscribers and organizations of water supply and sewerage facilities (WSS), water utilities. The methodological instructions of V.I.Danilov - Danilyan on the calculation of fees for unorganized discharge of pollutants into water bodies are not applied now. Payment must be made only for the discharge of pollutants and microorganisms into water bodies.

How to apply factor 2?

Coefficient 2 to the rates of fees for NVOS in accordance with Resolution No. 913 it is applied to territories and objects under special protection in accordance with federal laws. Here is a list of such territories and objects:

• specially protected natural areas;
• rare and endangered plants, animals and other organisms;
• green fund of urban and rural settlements;
• rare and endangered soils.

What are the possibilities for clarifying the Declaration?

If errors are found in the declaration (inaccurate or incomplete reflection of information, overstatement or understatement of the amount of the fee), the person obliged to pay the fee has the right to submit an updated Declaration. In this case, the revised Declaration must be submitted no later than March 10 of the year following the reporting year, i.e. at the same time as the original Declaration... It looks a little absurd, considering that the draft Order was given three years for this.

How to get overpaid money back?

Refund or offset of previously listed money carried out on the basis of the payer's application. The application form is currently arbitrary. The application must indicate the reason for the refund (for example, the refund of advance payments), the justification for the amount to be returned and the current account to which the overly transferred amounts should be returned. Copies of payment orders should be attached to the application.

Within 30 days from the date of registration of the payer's application, if a decision is made to return it, Rosprirodnadzor forms an application for a return and sends it to the Federal Treasury Department (UFK), and also sends the payer a written response about the decision.

Upon receipt of documents from the UFK on the return of funds, Rosprirodnadzor within 30 days must send the payer a written response and a document confirming the refund.

Upon receipt from the UFK of documents on refusal to return Rosprirodnadzor within 10 days is obliged to notify the payer in writing about the impossibility of returning the funds, indicating the reason.

The Ministry of Natural Resources of Russia adopted a departmental act, which approved the form and procedure for submitting a declaration on payment for a negative impact on the environment (Order of the Ministry of Natural Resources of Russia dated January 9, 2017 No. 3 "").

So, no later than March 10 of the year following the reporting year, the payers of this fee must submit a declaration to Rosprirodnadzor and attach the necessary documents to it. The submission format is provided electronically, through the "Personal Account" of the official site of Rosprirodnadzor. However, if the person obliged to pay the fee does not have an electronic signature or access to the Internet, the declaration of payment for 2016 may be submitted in hard copy (clauses 5-6 of the Procedure).

Let us remind you that payments for negative impact on the environment must be paid by
legal entities and individual entrepreneurs engaged in economic or other activities on the territory of Russia that have a negative impact on the environment. With the exception of legal entities and individual entrepreneurs that carry out economic or other activities exclusively at objects of category IV, which have a minimum negative impact on the environment. In particular, the payers of payments for the negative impact on the environment when disposing of waste, with the exception of solid municipal waste, are legal entities and individual entrepreneurs, in the course of which economic or other activities were generated. When placing solid municipal waste, the payers of this fee are regional operators for the handling of solid municipal waste, as well as operators for handling solid municipal waste, carrying out activities for their disposal (clause 1 of article 16.1 of the Federal Law of January 10, 2002 No. 7- FZ "