Declaration of payment for tax assessment: description and rules for filling out. An example of filling out a declaration on environmental fees. An example of filling out the tax assessment for the year.

Frequently asked questions regarding the Tax Fee Declaration

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 environmental impact (NEI), developed in accordance with the Order of the Ministry of Natural Resources dated January 09, 2017 No. 3.

This article contains questions that arise when drawing up the annual Declaration of payment for the NVOS.

We calculated the amount of the fee 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 tax assessments, except for small and medium-sized businesses, are required to make advance payments in the first and third quarters. The amount of the advance payment is equal to one-fourth of the payment amount for the previous year. At the same time, many natural resource 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 ends up overpaying, to the point that the advance payment for two quarters is more than the annual payment. And this is true, there is no mistake in it.

The fact is that on September 23, 2016, Decree of the Government of the Russian Federation No. 913 “On payment rates for high-improvement materials” 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 order has changed calculation of the fee amount. Thus, a number of increasing coefficients were abolished, such as the coefficient of environmental significance, coefficient 2 (for resort areas and the far north), and coefficient 1.2 (NVOS within the city). In addition, Order No. 3 of the Ministry of Natural Resources introduced a number of incentive reduction coefficients. 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 data from a real project was carried out in the article “Calculation of fees for pollution of environmental components: what has changed?” (magazine Ecologist's Handbook, No. 2, 2017). Here are the conclusions reached by the authors of this article: “... the amount of fees for 2016 will decrease for various types of impact on environmental components by approximately 40–70%, and for 2017 - by 30–70%.”

Who is required to submit the Declaration and pay for the NVOS?

The declaration is submitted by tax payers. If your organization, in accordance with Federal Law No. 7-FZ, is not required to pay a fee for the tax assessment, then you do not need to submit a Declaration of payment for the tax assessment.

And yet who is required to pay a fee for the NVOS? At the moment, we can say with confidence that the payers are legal entities and individual entrepreneurs carrying out economic activities on objects of categories I – III, and that objects of category IV are exempt from paying for the tax assessment. At the same time, business entities are exempt from paying for the disposal of municipal solid waste (MSW), the fee for which is paid by regional MSW management operators. In addition, it is possible for a number of waste disposal facilities (WDO) to obtain a decision from the territorial body

Rosprirodnadzor on eliminating negative impacts on the environment, allowing to reduce the amount of fees for the organization as a whole.

It would seem that we have gone through the procedure for registering 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 environmental impact assessment is not directly related to the definition of the facility providing environmental assessment, i.e. with registration of objects of the NVOS. Therefore, it is not yet clear what to do for objects that have been refused registration as not providing NVOS. The situation is aggravated by the fact that in 2016 there were no regional MSW management operators. Federal Law No. 486-FZ of December 28, 2016 “On Amendments to Certain Legislative Acts of the Russian Federation” established a transition period until January 1, 2019 for the introduction of public services for the management of solid waste and the establishment of a unified tariff on the territory of the constituent entities of the Russian Federation. Thus, until the date of approval of the unified tariff and the signing of agreements between the constituent entities of the Russian Federation and regional MSW operators, payment for the placement of MSW is carried out by business entities whose activities generate municipal solid waste.

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 the fee for the 2016 assessment, regardless of the registration of the facilities and the categories assigned to them. An exception may be small offices where the lease agreement clearly states that the payment for waste removal is paid by the lessor, who has entered into contracts for waste removal and is the payer of the fee for the NVOS.

Clarification. Rosprirodnadzor, in a letter dated 02/21/2017 No. AS-06-02-36/3591 “Who pays the fee for NVOS when placing MSW”, expressed its position regarding MSW, which is as follows: business entities that actually carry out licensed activities for the management of MSW, correspond status of MSW management operators, therefore, for 2016 and until the selection in the constituent entities of the Russian Federation of a regional operator for the management of MSW with a single tariff, in accordance with the law MSW fees are charged to MSW management operators carrying out specialized activities for the disposal of municipal solid waste.

Declaration form?

On February 22, 2017, Order of the Ministry of Natural Resources dated January 09, 2017 No. 3 “On approval of the Procedure for submitting a declaration on payment for negative impact on the environment and its forms” was registered with the Ministry of Justice and published, i.e. came into force.

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

The fee is paid separately for four environmental components: emission fee, associated gas emission fee, discharge fee and waste disposal fee. Each with its own BCC (budget classification code). It should be taken into account that if advance payments were made and, for example, there was an overpayment for waste, then it cannot be automatically included in the payment for emissions, because These components are paid according to different BCCs. The calculated total amounts of fees to be paid for the reporting period are subject to payment (lines 151 – 154 of the Declaration), fee amounts for 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. The Excel formatted Declaration form can be downloaded from our website.

Attention! In line 010 on the sheet “Calculation of the fee amount” of the Declaration, the code of the municipal entity (OKTMO) is indicated on the territory of which the stationary source or waste disposal facility (WDF) for production and consumption, it should not be confused with a waste generation facility. In the Declaration form, line 010 has 11 characters for entering OKTMO, but you only need to indicate the first 8 characters of OKTMO, and write zeros in the 10th and 11th positions.

What is the procedure for submitting the Declaration to Rosprirodnadzor?

When stationary NVOS and/or ORO facilities are located on the territory of different subjects of the Russian Federation, a separate Declaration must be submitted for each subject of the Russian Federation.

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

The declaration can be submitted separately for a separate division located outside the location of the organization itself. Let's consider two main types of separate divisions: branches, which are vested with all the rights and obligations of a legal entity at the place of registration of such a unit, and representative offices who represent the interests of a legal entity in a certain territory and protect them (the 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 based on a power of attorney pay a fee for NVOS. Representatives are deprived of this right.

The following documents must be attached to the Declaration of Fee for Tax Assessment:

  • a document confirming the authority of the person obliged to pay the fee to carry out actions on his behalf, if the Declaration of Fee is submitted by an authorized representative;
  • documents confirming the costs of environmental protection measures taken into account in the adjustment 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 possibility of connecting to the Internet or there is no digital signature, the Declaration can be provided on paper by the person obligated to pay the fee, in person, or through an authorized representative, or by registered mail with a description of the attachment and a receipt.

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

Starting from 01/01/2017, the Rosprirodnadzor portal pnv-rpn.ru stopped accepting reports; it will only be available for viewing previously submitted reports until 06/30/2017. Now the State Services portal located at lk.fsrpn.ru is used to receive reports. To submit reports, you must have an account on the State Services portal. You need to take care of this in advance, because... The registration procedure will take some time to collect the documents necessary for registration.

We can't find fee rates for pollutants

New payment rates were approved by Resolution No. 913, which brings the rates into line with the Order of the Government of the Russian Federation dated 06/08/2015 No. 1316-r “On approval of the list of pollutants for which state regulatory measures in the field of the environment are applied.”

The currently available permits for emissions and discharges were issued without taking into account Order No. 1316-r, which significantly reduces the list of pollutants and, as a consequence, the payment rates for them. For emissions and discharges of pollutants for which there are no payment rates, starting from 2016 there is no need to pay, even if these pollutants are listed in permits.

The established practice of using charge rates for pollutants with similar characteristics is illegal. Thus, in the Letter of Rosprirodnadzor dated January 16, 2017 N AS-03-01-31/502 “On consideration of the appeal” it was said that “...substances such as abrasive dust, carbon (soot), iron oxide, due to their physical properties , related to solid particles, it is advisable to take into account the emissions as suspended substances.” This and the requirements previously applied by the administrators of the fee for the NVOS to pay for pollutants that are not 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 can I get maximum permissible values ​​and VAT for 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, VAT and VAT, VSS of pollutants for each source and release separately. The permitting documentation approves the data for the facility as a whole. To obtain data in the context of sources and releases, you need to raise the project documentation, namely the standardization section.

How to calculate relief to relief?

People still ask how relief is calculated. The fee for the so-called stormwater drainage system was canceled back in 2014 (or rather, it was never approved and its application was unlawful). The discharge of wastewater is regulated by legal acts that define the relationship between subscribers and water supply and sewerage organizations (WSS) and water utilities. The methodological instructions of V.I. Danilov - Danilyan for calculating fees for unorganized discharge of pollutants into water bodies are not currently used. Payment must be made only for the discharge of pollutants and microorganisms into water bodies.

How to apply factor 2?

Coefficient 2 to the tax payment rates in accordance with Resolution No. 913, it applies 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 for urban and rural settlements;
  • rare and endangered soils.


What are the possibilities for clarifying the Declaration?

If errors are detected in the declaration (inaccurate or incomplete reflection of information, overestimation or underestimation of the amount of the fee), the person obliged to pay the fee has the right to provide an updated Declaration. In this case, the updated Declaration must be submitted no later than March 10 of the year following the reporting year, i.e. within the same period as the initial Declaration. It looks somewhat absurd, considering that the draft Order allocated three years for this.

How to get back overpaid money?

Refunds or credits of previously transferred funds are carried out based on the payer’s application. The application form is currently free. The application must indicate the reason for the return of funds (for example, return of advance payments), justification for the amount being returned and the bank account to which the excess transferred amounts should be returned. Copies of payment orders must be attached to the application.

Within 30 days from the date of registration of the payer’s application, in the event of a decision on a refund, Rosprirodnadzor forms an application for a refund and sends it to the Federal Treasury Department (UFK), and also sends a written response to the payer about the decision.

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

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

What form should I use to submit a declaration on payment for negative environmental impact for 2016? Where can I download the officially approved form? Who is required to submit a declaration in 2017? What are the deadlines for paying the fee and submitting the declaration to Rosprirodnadzor? You will find answers to these and other questions in this article, and you can also see a specific example of a completed declaration.

Who must submit a declaration in 2017

The Declaration of Negative Impact on the Environment for 2016 must be submitted by persons obligated to pay a fee for negative impact on the environment in accordance with Article 16.1 of the Federal Law of January 10, 2002 No. 7-FZ “On Environmental Protection”. reported on the Rosprirodnadzor website.

Payments for environmental pollution, in turn, are required to be paid to the budget by all organizations and individual entrepreneurs that use facilities in their activities that have a negative impact on the environment. In this case, the applied tax regime (STS, OSNO or UTII) does not matter (Article 23 of the Federal Law of June 24, 1998 No. 89-FZ, Article 28 of the Federal Law of May 4, 1999 No. 96-FZ). Moreover, it does not matter on what right organizations or individual entrepreneurs use the object of negative impact (whether the object is owned or leased).

Objects of negative impact: what are they?

Objects that have a negative impact on the environment (NEI), depending on the level of such impact, are divided into four categories (Article 4.2 of the Federal Law of January 10, 2002 No. 7-FZ):
Categories of NVH objects
Category Characteristic
I categoryObjects that have a significant negative impact on the environment and are related to the areas of application of the best available technologies.
II categoryObjects that have a moderate negative impact on the environment.
III categoryObjects that have a minor negative impact on the environment.
IV categoryObjects that have minimal negative impact on the environment.

At the same time, organizations and individual entrepreneurs are not required to pay a fee for environmental pollution if they operate only at objects of hazard category IV (clause 1 of Article 16.1 of Law No. 7-FZ of January 10, 2002). These are objects on which:

  • there are stationary sources of pollutant emissions, 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 water is used for industrial needs, into sewers and into the environment (into surface and underground water bodies, onto the earth's surface).
Such objects (4 categories) include, for example, offices.

Advice

Check whether the facilities operated by the organization or individual entrepreneur comply with hazard category IV. Rosprirodnadzor assigns hazard categories when registering objects in the state register. Accordingly, you can contact the Rosprirodnadzor unit and find out the class of your object (if you previously entered it into the register). If it turns out that you have category IV, 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 entity of the Russian Federation, shows, among other things, the names of the organization (IP) and the object belonging to it that has a negative impact on the environment.

Payment deadline for 2016

The amount of payment for negative environmental impact should be determined based on the results of the year 2016. This fully applies to small and medium-sized businesses. They are required to pay the payment for 2016 no later than March 1, 2017 (inclusive).

Who is required to make advances?

In 2016, large businesses were required to make quarterly advance payments for the negative impact fee: no later than the 20th day of the month following the last month of the quarter. The payment amount in 2016 was 1/4 of the amount actually paid (and not accrued!) for the 1st-4th quarters of 2015. In 2017, advance payments to large businesses are required to be calculated from the amounts of fees paid for 2016 and indicated in the declaration of fees for negative environmental impact. Also see: "".

New declaration form for 2016 and due date

For 2016, organizations and individual entrepreneurs obliged to pay a fee for pollution must report to Rosprirodnadzor using a new form of declaration on payment for negative impact on the environment. You can download the new bank, approved by Order of the Ministry of Natural Resources dated January 9, 2017 No. 3. Also, the indicated Order of the Ministry of Natural Resources approved the procedure for submitting a declaration on payment for negative impact on the environment. The deadline for submitting the declaration for 2016 is no later than March 10, 2017.

At the same time, it is worth noting that a rather strange situation occurred with the approval of the form for the new declaration on the NVOS in 2017. The fact is that the new form of declaration and the procedure for its submission were registered by the Ministry of Justice of Russia only on February 22, 2017 No. 45747. These documents were also officially published on February 22. 2017 on the official resource for publishing regulations. Consequently, these documents officially come 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. Before this date, the declaration, in fact, cannot be applied. Moreover, until 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, March 4 and 5, 2017 are Saturday and Sunday. March 8 is a festive International Women's Day. These days, most businesses are not open. Also, the divisions of Rosprirodnadzor do not work in these areas. It turns out that in 2017, businesses have only 4 working days to prepare and submit a declaration: March 6, 7, 9 and 10. Moreover, March 7 is a shortened working day.

How and where to submit an electronic declaration?

The declaration of payment for negative impact for 2016 can be generated exclusively in electronic form using special electronic services developed by Rosprorodnadzor. This is provided for in paragraph 4 of the Procedure approved by Order of the Ministry of Natural Resources dated January 9, 2017 No. 3. In other words, you cannot simply print out the form and fill it out with a pen. You need to use a special program to fill out and generate an electronic file with the declaration.

As for the transfer of the generated file to the bodies of Rosprirodnadzor, then, as a general rule, you need to send the declaration for 2016 via the Internet using the “Personal Account” account on the Rosprirodnadzor website. To prepare and submit the 2016 NEI declaration, you will need the following:

Install the module and fill out the declaration

You can generate a declaration for 2016 using the environmental user module version 3.8. This module was posted on the Rosprirodnadzor website on 02/22/2017 and takes into account the new declaration form approved by Order of the Ministry of Natural Resources dated 01/09/2017 No. 3. reported on the website of Rosprirodnadzor.

In the Environmental User Reporting section, you can click on the “Nature User Module” and download a free program for filling out a declaration.

Log in to the personal account of an organization or individual entrepreneur

On the Rosprirodznazor website you will need to log into the personal account of the natural resource user to prepare and submit reports to Rosprirodnadzor. You can enter it at https://lk.fsrpn.ru. You can log in, in particular, using the login and password used on the State Services portal. Also at the specified address, instructions are provided on what is necessary to access the office and generate reports. Familiarize yourself with it if you have not used your personal account before.

Have a digital signature

You can submit a 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 declaration file and submit it to Rosprirodnadzor. If you do not have an electronic signature, you will not be able to report electronically.

When can you report “on paper”?

You can submit a declaration on payment for negative environmental impact for 2016 in paper form only if (clauses 5 and 6 of the Procedure for submitting a declaration, approved by Order of the Ministry of Natural Resources dated 01/09/2017 No. 3):
  • the annual fee for negative impact for 2016 was less than 25,000 rubles;
  • there is no technical ability to connect to the Internet;
  • no electronic digital signature.
The “paper” declaration on the NVOS must be submitted no later than March 10, 2017 to the territorial bodies of the Federal Service for Supervision of Natural Resources (Rosprirodnadzdor) at the place of registration of the facility that has a negative impact on the environment, the facility where production and consumption waste is disposed of. However, when submitting a “paper” declaration, you are also required to provide a copy of the declaration on a flash drive or other electronic media. That is, even if you have the right to report in paper format, you will still need to use the electronic service on the Rosprirodnadzor website to generate a declaration file. Then this declaration will need to be printed and the printed document and electronic file submitted to the Rosprirodnazdor authorities.

What if there are several objects?

If “negative” objects are located in different constituent entities of the Russian Federation, then separate declarations for each object must be submitted to the relevant bodies of Rosprirodnadzor. If the objects are located in one subject of the Russian Federation, then one declaration is submitted (clause 8 of the Procedure for submitting a declaration, approved by Order of the Ministry of Natural Resources dated January 9, 2017 No. 3).

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

Composition of the new declaration

The new form of declaration of payment for negative impact on the environment, approved by Order of the Ministry of Natural Resources dated January 9, 2017 No. 3, consists of the following sections:
  • title page of the declaration (includes general information about the company or individual entrepreneur);
  • calculation of the amount of fees to be paid into the budget (indicating the BCC);
  • Section 1. Calculation of the amount of payment for emissions of pollutants into the atmosphere 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 without exceeding the volume corresponding to the maximum permissible value of the combustion indicator;
  • Section 1.2. Calculation of the amount of payment for emissions of pollutants generated by flaring and (or) dispersion of associated petroleum gas when the volume corresponding to the maximum permissible value of the combustion indicator is exceeded;
  • 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 out the declaration: sample

As we have already said, organizations and individual entrepreneurs will not need to fill out the declaration “manually”. However, we believe it would be advisable to explain some aspects of filling out that should be paid attention to so that the declaration for 2016 can be checked and pass format and logical control the first time. So, when filling out, adhere to the following basic principles:
  • persons obliged to make payments for nagative and provide a declaration must include in it only those sections for which they have such an obligation;
  • all numerical indicators, except TIN and KPP, are indicated by filling out the cells, starting from the smallest digit of the number, from right to left, zeros are not indicated in empty cells;
  • Fee amounts are indicated in rubles accurate to one hundredth. Rounding is done in accordance with the mathematical rounding order.

Title page

On the title page, indicate general information “about yourself.” In particular, you will need to indicate:
  • organizational and legal form;
  • name of the organization or full name of the entrepreneur;
  • telephone;
  • TIN and checkpoint;
  • Full name and signatures of the manager and chief accountant.

Calculation of the amount of fees to be included in the budget

Calculation of the amount to be contributed to the budget includes indicators of payment amounts, including by type, for each facility providing NVOS. This declaration sheet is filled out for each municipality separately.

Line 010 indicates the code of the corresponding municipal entity - 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 of payment amounts, without taking into account the adjustment of their size. The indicator for this line must be formed as the sum of fees for all types of tax assessments and include in it payments calculated:

  • within the limits of permissible emissions standards (APE),
  • 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 disposal of production and consumption waste and above the specified limits.
The amount for line 020 in the table is determined in the following order: line 020 = line 021 + line 022 + line 023 + line 024
Lines 021, 022, 023 and 024 indicate the components of the payment amount by type of tax assessment, the values ​​of which are taken equal to the value of the indicator of the corresponding line:
  • page 021 = page 040;
  • page 022 = page 060;
  • page 023 = page 080;
  • page 024 = page 100.
Line 031 indicates OKTMO of stationary sources specified in Section 1 “Calculation of the amount of payment for a negative impact facility for emissions of pollutants into the air by stationary facilities.”

Line 040 reflects the amount of payment for emissions of pollutants into the air by stationary objects, calculated for each stationary source, without adjusting its size.

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

Line indicator 040 = total according to column 17 of Section 1, line “Total for stationary sources”.
Indicators in lines 041, 042 and 043 are decipherable to the amount reflected in line 040. All data for filling them out is contained in Section 1.

Line 041 reflects the amount of payment for emissions within the maximum permissible limit; the amount must correspond to the total in column 14 of Section 1, line “Total for stationary sources.”
Line 042 reflects the amount of payment for emissions within the limits for emissions of pollutants (VER), the amount must correspond to the total in column 15 of Section 1, line “Total for stationary sources.”

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

Other calculation lines are filled in similarly. Each indicator must correspond to the total calculation amounts for the corresponding section.

Lines 060 to 063 reflect the amounts of fees for emissions of pollutants during flaring and/or dispersion of associated petroleum gas, calculated for all stationary sources (flares, dispersion installations). This is what a sample calculation of the fee amount may look like, in which the BCC is indicated:

Section 1. Calculation of fees for emissions into atmospheric air

In section 1 of the declaration for 2016, it is necessary to provide a calculation of the amount of payment for emissions of pollutants into the air by stationary objects. The section must include data on each such object. When filling out Section 1, indicate:
  • number, date of issue and validity period of the permit for the emission of pollutants into the air.

Section 1.1

Section 1.1 must be completed by persons obligated to pay a fee, releasing harmful (pollutant) substances into the atmospheric air from sources of combustion and (or) dispersion of associated petroleum gas without exceeding the volume corresponding to the maximum permissible value of the combustion indicator and, in established cases, not using it , for each stationary source (flare, dispersion installation) of an object that has a negative impact on the environment. As part of the declaration, this section looks like this:

If the above combustion was not carried out, then there is no need to fill out this section and include it in the declaration for 2016.

Section 1.2

This section should be compiled by persons obligated to pay a fee, emitting pollutants into the atmospheric air during flaring and (or) dispersion of associated petroleum gas in volumes that exceed the maximum permissible value of the combustion index (Zpr), or in the absence of a measurement system and accounting for the volume of associated petroleum gas for each stationary source (flare unit, dispersion unit) of the facility that has a negative impact on the environment. This section consists of the following table:

Section 2. Calculation of fees for discharges into water bodies

Section 2 is filled out by a person obligated to pay a fee, who has discharges of waste and (or) drainage water into water bodies and their parts, for each discharge of an object that has a negative impact on the environment. When filling out section 2, indicate:
  • category of an object that has a negative impact on the environment;
  • name of the object that has a negative impact on the environment;
  • code of an object that has a negative impact on the environment;
  • address of the location of the facility that has a negative impact on the environment;
  • number, date of issue and validity period of the permit for the discharge of pollutants into the environment.
This section, without filling, looks like this:

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

Section 3 is completed for each negative impact facility and waste disposal facility separately. If the person obligated to pay the fee has an object that has a negative impact on the environment and a waste disposal facility that does not belong to the person obligated to pay the fee, this section is filled out separately for the object of negative impact and the waste disposal facility. It states:
  • category of an object that has a negative impact on the environment;
  • name of the object that has a negative impact on the environment;
  • code of an object that has a negative impact on the environment;
  • address of the location of the facility that has a negative impact on the environment;
  • information about the category of the object (not filled in if the negative impact (waste disposal facility) does not belong to the person obligated to pay the fee);
  • details of the document approving waste generation standards and limits on their disposal (date of issue, number, validity period, by whom issued);
  • for small and medium-sized businesses, the characteristics of the reporting submitted for the reporting period on the generation, use, neutralization and disposal of waste (sent by mail/electronically), as well as the details of this reporting:
  • when sent by post, indicate the date of dispatch and the name of the recipient (territorial body of the Federal Service for Supervision of Natural Resources, executive body of a constituent entity of the Russian Federation);
  • in case of sending in electronic form (date, number assigned on the web portal for receiving reports of the Federal Service for Supervision of Natural Resources, or date and number assigned on web portals for receiving reports of executive authorities of the constituent entities of the Russian Federation that accept reports, and also the recipient of the reporting (territorial body of the Federal Service for Supervision of Natural Resources, executive authority of a constituent entity of the Russian Federation);
  • address of the location of the waste disposal facility;

Section 3.1: Municipal Solid Waste Disposal Fees

Section 3.1 is completed by regional operators for the management of municipal solid waste, operators for the management of municipal solid waste, carrying out burial activities, for each object of negative impact, waste disposal facility separately. When filling out Section 3, indicate:
  • category of an object that has a negative impact on the environment;
  • name of the object that has a negative impact on the environment;
  • code of an object that has a negative impact on the environment;
  • address of the location of the facility that has a negative impact on the environment;
  • information about the category of the facility (not filled in if the waste disposal facility does not belong to the person obligated to pay the fee);
  • name of the waste disposal facility;
  • registration number (if assigned) of the waste disposal facility;
  • 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).

Responsibility

Payments for negative environmental impact are not a tax. Therefore, it is impossible to fine under the Tax Code for late submission of a declaration on these payments. It is also impossible, for example, to block the current accounts of an organization or individual entrepreneur who has not submitted a declaration. However, it is possible to bring administrative liability for distortion of data in the declaration or untimely submission in accordance with Article 8.5 of the Code of Administrative Offenses of the Russian Federation. The following administrative fines are in effect in 2017:
  • for officials (for example, for a director or chief accountant) - from 3,000 to 6,000 rubles;
  • for individual entrepreneurs - from 3,000 to 6,000 rubles (they are fined as officials)
  • for legal entities - from 20,000 to 80,000 rubles.

Key questions

Persons obligated to pay fees

The procedure for determining the payment base

The procedure for submitting a declaration of payment for the NVOS and its form

Comments on filling out the declaration

Submitting a declaration and paying a fee

Adjustment of the declaration

Fee rates and odds

2017 brings with it many innovations in environmental legislation. One of the areas that has undergone changes is the fee for negative environmental impact (hereinafter referred to as NVOS).

Federal Law No. 7-FZ dated January 10, 2002 “On Environmental Protection” (as amended on July 3, 2016; hereinafter referred to as Federal Law No. 7-FZ) lays down the basis for payment for environmental impact assessments. So, in accordance with Art. 16 of Federal Law No. 7-FZ, fees for NVOS are charged for the following types:

Emissions of pollutants into the atmospheric air from stationary sources;

Discharges of pollutants into water bodies;

Storage and burial of production and consumption waste (waste disposal).

Persons obligated to pay fees

Legal entities and individual entrepreneurs carrying out economic and (or) other activities that provide economic impact on the territory of the Russian Federation, the continental shelf of the Russian Federation and in the exclusive economic zone of the Russian Federation, with the exception of legal entities and individual entrepreneurs carrying out economic and (or) other activities exclusively at category IV facilities.

Payers of fees for NWOS when disposing of waste, with the exception of municipal solid waste (hereinafter referred to as MSW), are legal entities and individual entrepreneurs whose economic and (or) other activities generated waste.

Payers of the fee for the NVOS when placing MSW are regional operators for the management of MSW, operators for the management of MSW, carrying out activities for their placement.

In light of the work on registering facilities that provide NVOS, Rosprirodnadzor has prepared a number of clarifications, according to which the issues of calculating and collecting fees for NVOS are not directly related to the definition of a facility that provides NVOS. However, it is still unknown what to do for facilities that are recognized as not providing NVOS.

The procedure for determining the payment base

The procedure for determining the payment base is regulated by Art. 16.2 of Federal Law No. 7-FZ.

The payment base for calculating the fee for environmental waste is the volume or weight of emissions of pollutants, discharges of pollutants, or the volume or weight of production and consumption waste disposed of during the reporting period.

The payment base is determined by persons obliged to pay independently on the basis of production environmental control data for each stationary source actually used during the reporting period, in relation to each pollutant included in the list of pollutants, hazard class of production and consumption waste.

When determining the payment base, the volume and (or) mass of emissions of pollutants, discharges of pollutants within the limits of permissible emission standards, permissible discharge standards, temporarily permitted emissions, temporarily permitted discharges exceeding such standards, emissions and discharges (including emergency), as well as Limits on the disposal of production and consumption waste and their exceeding are taken into account.

The procedure for submitting a declaration of payment for the NVOS and its form

The procedure for submitting the declaration is determined by Art. 16.4 of Federal Law No. 7-FZ, as well as the still draft Order of the Ministry of Natural Resources of Russia “On approval of the Procedure for submitting a declaration on payment for negative impact on the environment and its forms.”

Structure of the declaration of payment for negative environmental impact

Title page.
Calculation of the payment amount to be paid to the budget.
Section 1. Calculation of the amount of payment for an object of negative impact for emissions of pollutants into the air by stationary objects.
Section 1.1. Calculation of the amount of payment for an object of negative impact for emissions of pollutants into the air during flaring and (or) dispersion of associated petroleum gas without exceeding the integral combustion indicator.
Section 1.2. Calculation of the amount of payment for an object of negative impact for emissions of pollutants into the atmospheric air during flaring and (or) dispersion of associated petroleum gas when the integral combustion indicator is exceeded.
Section 2. Calculation of the amount of payment for an object of negative impact for the discharge 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.

Comments on filling out the declaration

For each subject of the Russian Federation, persons obliged to pay a fee submit a separate declaration.

Each page of the declaration submitted by the person obligated to pay the fee, on paper, after the words “I confirm the accuracy and completeness of the information indicated on this page,” must be signed by the executor (indicating the position, surname, name and patronymic) indicating the date of signing.

Section 1

When filling out section 1, indicate:

Number, date of issue and validity period of the permit to emit pollutants into the air.

Section 1 presents data on stationary sources and specific substances emanating from each source.

Section 1.1

When filling out section 1.1, indicate:

Name of the facility providing NVOS;

Code of the facility providing NVOS;

Address of the location of the facility providing NVOS;

Method of calculation (aggregation or differentiation) of the integral indicator of combustion (dispersion) of associated petroleum gas (hereinafter referred to as APG);

APG production volume (million m3);

Section 1.2

Section 1.2 is filled out by a person obligated to pay a fee, emitting pollutants into the atmospheric air when flaring and (or) dispersing APG in volumes that exceed the maximum permissible value of the combustion index (Z pr), or in the absence of a system for measuring and accounting for volumes APG for each stationary source (flare unit, dispersion unit) of the facility providing NVES.

The maximum permissible value of the indicator of flaring and (or) APG dispersion (Z pr ≤ 5%) and the specifics of calculating the fee are determined by the Decree of the Government of the Russian Federation dated November 8, 2012 No. 1148 “On the specifics of calculating fees for the negative impact on the environment during emissions into the atmosphere.” air pollutants generated during combustion in flares and (or) dispersion of associated petroleum gas" (as amended on December 17, 2016).

When filling out section 1.2, indicate:

Name of the facility providing NVOS;

Code of the facility providing NVOS;

Address of the location of the facility providing NVOS;

Number, date of issue and validity period of the permit for the emission of pollutants into the air;

Method of calculation (aggregation or differentiation) of the integral indicator of APG combustion (dispersion);

APG production volume (million m3);

Volume of APG combustion (million m3);

Volume of APG use (excluding process losses) (million m3);

Technological losses (million m3);

APG utilization rate (%).

Section 2

Section 2 is filled out by a person obligated to pay a fee, who has discharges of waste and (or) drainage waters into water bodies and their parts, for each discharge of a facility providing NVOS.

When filling out section 2, indicate:

Name of the facility providing NVOS;

Code of the facility providing NVOS;

Address of the location of the facility providing NVOS;

Number, date of issue and validity period of the permit for the discharge of pollutants into the environment.

Section 3

Section 3 is filled out for each facility providing NVOS, waste disposal facility (hereinafter referred to as WRO) separately.

If a person obligated to pay a fee has a facility that provides NVOS and an ORO that does not belong to this person, section 3 is filled out separately for the facility that provides NVOS and the ORO.

All operations with waste are reflected in calculations for the reporting period in which this operation was reflected in accounting in accordance with the established procedure.

Name of the facility providing NVOS;

Code of the facility providing NVOS;

Address of the location of the facility providing NVOS;

Details of the document on approval of waste generation standards and limits on their disposal (date of issue, number, validity period, by whom issued);

For small and medium-sized businesses (hereinafter referred to as SMEs) - characteristics of the reporting submitted for the reporting period on the generation, use, neutralization and disposal of waste (sent by mail/electronically), as well as the details of this reporting;

Name of ORO;

ORO location address;

Characteristics of the waste disposal facility (included/not included in the state register of waste disposal facilities (hereinafter referred to as GRRORO); does not provide NVOS).

Section 3.1

Section 3.1 is filled out by regional MSW management operators, MSW management operators carrying out burial activities, for each facility providing NVOS, OPO separately.

When filling out section 3, indicate:

Name of the facility providing NVOS;

Code of the facility providing NVOS;

Address of the location of the facility providing NVOS;

Name of ORO;

Registration number (if assigned) ORO;

ORO location address;

Characteristics of ORO (included/not included in GRRO; does not provide NVOS).

If the ORO does not provide NVOS, which is confirmed by the decision of the territorial body of Rosprirodnadzor to exclude the NVOS for this facility, sent to the person operating the ORO, the details of such a decision are indicated.

Submitting a declaration and paying a fee

The reporting period for payment of fees for the tax assessment is a calendar year.

The fee calculated based on the results of the reporting period, taking into account the adjustment of its amount, is paid no later than March 1 the year following the reporting period.

Persons obligated to pay the fee, with the exception of SMEs, 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 of the fee for the tax assessment paid for the previous year.

No later than March 10 of the year following the reporting period, persons obliged to pay a fee submit to the federal executive body authorized by the Government of the Russian Federation at the location of the facility providing NVOS, a declaration on the payment for NVOS.

Late or incomplete payment of the fee for the tax assessment by persons obligated to pay the fee entails the payment of penalties in the amount of one three hundredth of the key rate of the Bank of Russia in effect on the day of payment of the penalties, but not more than two tenths of a percent for each day of delay.

Penalties are accrued for each calendar day of delay in fulfilling the obligation to pay for the NVOS starting from the next day after the end of the relevant period specified in clause 3 of Art. 16.4 of Federal Law No. 7-FZ.

The following documents are attached to the completed declaration:

A document confirming the authority of the person obligated to pay the fee to carry out actions on his behalf - if the declaration is submitted by an authorized representative of the person obligated to pay the fee;

A register (list) of objects and documents confirming the use of funds for environmental protection measures taken into account when adjusting the amount of the fee - if the person obliged to pay the fee adjusted its amount in the reporting year.

Presentation options declarations:

Presentation option

date of receipt

In the form of an electronic document signed with an electronic signature, submitted through information and telecommunication networks

Date of departure via information and telecommunication networks

In the form of an electronic document submitted via information and telecommunication networks through the operator of the electronic document management system

The date recorded in the dispatch date confirmation

On paper - if it is not technically possible to submit a declaration in the form of an electronic document

A note from the territorial body of Rosprirodnadzor on receipt of the declaration indicating the date stamped on paper or the date of mailing

Upon acceptance of the declaration end result are:

1) the person obligated to pay the fee, personally:

a) affixing by the official of the territorial body of Rosprirodnadzor carrying out the reception a note on the acceptance of the declaration and the date of its acceptance;

b) oral communication about the refusal to accept the declaration;

2) in case of submitting a declaration by mail:

a) registration of the declaration with the territorial body of Rosprirodnadzor;

b) notice of refusal to accept the declaration sent to the applicant by mail;

3) in case of submitting a declaration in the form of an electronic document via information and telecommunication channels:

a) registration of the declaration on the web portal for receiving reports of Rosprirodnadzor;

b) notification of refusal to accept the declaration (error message).

If there is at least one of the following grounds the declaration will be refused:

Submission of a declaration not in the established form (established format);

Absence of attachments in the declaration;

The absence in the declaration submitted on paper of the signatures of persons authorized to confirm the accuracy and completeness of the information specified in the declaration, the seal of the person obliged to pay the fee (if, in accordance with the law, the person submitting the declaration must have a seal);

The absence in the declaration of payment, submitted in the form of an electronic document, of an electronic signature of persons authorized to confirm the accuracy and completeness of the information specified in the declaration, or a discrepancy between the data of the owner of a qualified certificate and the data of the person authorized to confirm the accuracy and completeness of the information.

Adjustment of the declaration

If it is discovered in the declaration that information is not reflected or is incompletely reflected, as well as errors, leading to an underestimation of the payment amount obliged make the necessary changes to the declaration and submit an updated declaration.

If a person obligated to pay a fee discovers inaccurate information or errors in the declaration submitted by him, not leading to an underestimation of the payment amount, the person obligated to pay the fee, has the right include the necessary changes in the declaration and submit an updated declaration.

In this case, an updated declaration submitted after the expiration of the established deadline for filing the declaration is not considered submitted in violation of the deadline.

If an updated declaration is submitted before the deadline for filing the declaration, it is considered submitted on the day the updated declaration is submitted.

The updated declaration is submitted in the form that was in force during the reporting period for which appropriate changes are made.

An updated declaration is submitted in the following cases:

Errors, incl. technical, leading to an underestimation of the amount of payment;

Discrepancies between the fee amounts indicated in the primary declaration and the actual provision of the IEE;

Inconsistencies between the applied fee rates and the coefficients in the primary declaration;

Discrepancies between the fee amounts specified in the primary declaration and the actual provision of the environmental protection system, identified during control activities, verification of production control results, reporting, submission of supporting documents for the purpose of applying reduction factors established by environmental protection legislation when calculating fees for waste disposal, offset of actual costs incurred for environmental protection measures and implementation of projects for the beneficial use of APG.

The maximum period for submitting an updated declaration on the fee is three years from the date of fixing the date of receipt of the initial declaration.

Fee rates and odds

The fee rates are approved by Decree of the Government of the Russian Federation dated September 13, 2016 No. 913 “On fee rates for negative environmental impacts and additional coefficients” (hereinafter referred to as Decree No. 913).

In order to encourage legal entities and individual entrepreneurs to take measures to reduce the NVOS and introduce the best available technologies (hereinafter referred to as BAT), when calculating fees for NVOS, the following coefficients will be applied to the rates of such fees from 01/01/2020:

. coefficient 0— for the volume or mass of emissions of pollutants, discharges of pollutants within the limits of technological standards after the implementation of BAT at the facility providing NVOS;

. coefficient 0- for the volume or mass of production and consumption waste subject to accumulation and actually used from the moment of generation in its own production in accordance with technological regulations or transferred for use within the period provided for by the legislation of the Russian Federation in the field of waste management;

. coefficient 1— for the volume or mass of emissions of pollutants, discharges of pollutants within the limits of permissible emission standards, permissible discharge standards;

. coefficient 1— for the volume or weight of production and consumption waste disposed within the limits for their placement, as well as in accordance with reporting on the generation, use, neutralization and disposal of production and consumption waste, submitted in accordance with the legislation of the Russian Federation in the field of waste management;

. coefficient 25— for the volume or mass of emissions of pollutants, discharges of pollutants within the limits of temporarily permitted emissions, temporarily permitted discharges;

. coefficient 25- for the volume or weight of production and consumption waste disposed in excess of the established limits for their disposal or specified in the environmental impact statement, as well as in reporting on the generation, use, neutralization and disposal of production and consumption waste, submitted in accordance with the law Russian Federation in the field of waste management;

. coefficient 100- for the volume or weight of emissions of pollutants, discharges of pollutants exceeding the volume or weight established for objects of category I, and also exceeding such volume or weight specified in the environmental impact declaration for objects of category II.

In order to encourage legal and individual entrepreneurs carrying out economic and (or) other activities to take measures to reduce the waste pollution when calculating the charge for waste disposal, the following coefficients are applied to the rates of such payment:

. coefficient 0— when placing waste of the V hazard class of the mining industry by filling artificially created cavities in rocks during the reclamation of land and soil cover (in accordance with the section of the project documentation “List of environmental protection measures” and (or) the technical project for the development of a mineral deposit);

. coefficient 0.3— when placing production and consumption waste that was generated in one’s own production, within the established limits for their placement in waste disposal facilities owned by a legal entity or individual entrepreneur on the right of ownership or other legal basis and equipped in accordance with established requirements;

. coefficient 0.5— when disposing of waste of IV, V hazard classes, which was formed during the disposal of previously disposed waste from the processing and mining industries;

. coefficient 0.67— when placing waste of hazard class III, which was formed during the neutralization of waste of hazard class II;

. coefficient 0.49— when disposing of waste of hazard class IV, which was formed during the neutralization of waste of hazard class III;

. coefficient 0.33— when placing waste of hazard class IV, which was formed during the neutralization of waste of hazard class II.

Regulation.gov.ru/projects#npa=20202

At the time of signing the issue for printing, Order of the Ministry of Natural Resources of Russia dated January 09, 2017 No. 3 “On approval of the Procedure for submitting a declaration on payment for negative impact on the environment and its forms” is being registered with the Ministry of Justice of Russia.

Declaration of payment for negative environmental impact for 2016: form and sample

The Declaration of Negative Impact on the Environment for 2016 must be submitted by persons obligated to pay a fee for negative impact on the environment in accordance with Article 16.1 of the Federal Law of January 10, 2002 No. 7-FZ “On Environmental Protection”. reported on the website

Payments for environmental pollution, in turn, are required to be paid to the budget by all organizations and individual entrepreneurs that use facilities in their activities that have a negative impact on the environment. In this case, the applied tax regime (STS, OSNO or UTII) does not matter (Article 23 of the Federal Law of June 24, 1998 No. 89-FZ, Article 28 of the Federal Law of May 4, 1999 No. 96-FZ). Moreover, it does not matter on what right organizations or individual entrepreneurs use the object of negative impact (whether the object is owned or leased).

Objects of negative impact: what are they?

Objects that have a negative impact on the environment (NEI), depending on the level of such impact, are divided into four categories (Article 4.2 of the Federal Law of January 10, 2002 No. 7-FZ):

Categories of NVH objects
Category Characteristic
I category Objects that have a significant negative impact on the environment and are related to the areas of application of the best available technologies.
II category Objects that have a moderate negative impact on the environment.
III category Objects that have a minor negative impact on the environment.
IV category Objects that have minimal negative impact on the environment.

At the same time, organizations and individual entrepreneurs are not required to pay a fee for environmental pollution if they operate only at objects of hazard category IV (clause 1 of Article 16.1 of Law No. 7-FZ of January 10, 2002). These are objects on which:

  • there are stationary sources of pollutant emissions, 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 water is used for industrial needs, into sewers 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 comply with hazard category IV. Rosprirodnadzor assigns hazard categories when registering objects in the state register. Accordingly, you can contact the Rosprirodnadzor unit and find out the class of your object (if you previously entered it into the register). If it turns out that you have category IV, 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 entity of the Russian Federation, shows, among other things, the names of the organization (IP) and the object belonging to it that has a negative impact on the environment.

Payment deadline for 2016

The amount of payment for negative environmental impact should be determined based on the results of the year 2016. This fully applies to small and medium-sized businesses. They are required to pay the payment for 2016 no later than March 1, 2017 (inclusive).

Who is required to make advances?

In 2016, large businesses were required to make quarterly advance payments for the negative impact fee: no later than the 20th day of the month following the last month of the quarter. The payment amount in 2016 was 1/4 of the amount actually paid (and not accrued!) for the 1st-4th quarters of 2015. In 2017, advance payments to large businesses are required to be calculated from the amounts of fees paid for 2016 and indicated in the declaration of fees for negative environmental impact. Also see: “Fee rates for negative environmental impact for 2017.”

New declaration form for 2016 and due date

For 2016, organizations and individual entrepreneurs obliged to pay a fee for pollution must report to Rosprirodnadzor using a new form of declaration on payment for negative impact on the environment. You can download the new one approved by Order No. 3 of the Ministry of Natural Resources dated 01/09/2017 using this link in Excel format. Also, the indicated Order of the Ministry of Natural Resources approved the procedure for submitting a declaration on payment for negative impact on the environment. The deadline for submitting the declaration for 2016 is no later than March 10, 2017.

At the same time, it is worth noting that a rather strange situation occurred with the approval of the form for the new declaration on the NVOS in 2017. The fact is that the new form of declaration and the procedure for its submission were registered by the Ministry of Justice of Russia only on February 22, 2017 No. 45747. These documents were also officially published on February 22. 2017 on the official resource for publishing regulations. Consequently, these documents officially come 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. Before this date, the declaration, in fact, cannot be applied. Moreover, until 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, March 4 and 5, 2017 are Saturday and Sunday. March 8 is a festive International Women's Day. These days, most businesses are not open. Also, the divisions of Rosprirodnadzor do not work in these areas. It turns out that in 2017, businesses have only 4 working days to prepare and submit a declaration: March 6, 7, 9 and 10. Moreover, March 7 is a shortened working day.

How and where to submit an electronic declaration?

The declaration of payment for negative impact for 2016 can be generated exclusively in electronic form using special electronic services developed by Rosprorodnadzor. This is provided for in paragraph 4 of the Procedure approved by Order of the Ministry of Natural Resources dated January 9, 2017 No. 3. In other words, you cannot simply print out the form and fill it out with a pen. You need to use a special program to fill out and generate an electronic file with the declaration.

As for the transfer of the generated file to the bodies of Rosprirodnadzor, then, as a general rule, you need to send the declaration for 2016 via the Internet using the “Personal Account” account on the Rosprirodnadzor website. To prepare and submit the 2016 NEI declaration, you will need the following:

Install the module and fill out the declaration

You can generate a declaration for 2016 using the module version 3.8. This module was posted on the Rosprirodnadzor website on 02/22/2017 and takes into account the new declaration form approved by Order of the Ministry of Natural Resources dated 01/09/2017 No. 3. reported on the Rosprirodnadzor website.

In the Environmental User Reporting section, you can click on the “Nature User Module” and download a free program for filling out a declaration.

Log in to the personal account of an organization or individual entrepreneur

On the Rosprirodznazor website you will need to log into the personal account of the natural resource user for preparation and Rosprirodnadzor. You can enter it at https://lk.fsrpn.ru. You can log in, in particular, using the login and password used on the State Services portal. Also at the specified address there are instructions on what is needed to access your account and read it if you have not used your personal account before.

Have a digital signature

You can submit a declaration through your personal account on the Rosprirodnadzor website only with the attachment of an electronic digital signature issued by the center. With this signature you will need to sign the declaration file and submit it to Rosprirodnadzor. If you don’t have one, then you won’t be able to report electronically.

When can you report “on paper”?

You can submit a declaration on payment for negative environmental impact for 2016 in paper form only if (clauses 5 and 6 of the Procedure for submitting a declaration, approved by Order of the Ministry of Natural Resources dated 01/09/2017 No. 3):

  • the annual fee for negative impact for 2016 was less than 25,000 rubles;
  • there is no technical ability to connect to the Internet;
  • no electronic digital signature.

The “paper” declaration on the NVOS must be submitted no later than March 10, 2017 to the territorial bodies of the Federal Service for Natural Resources Management (Rosprirodnadzdor) at the place of registration of the facility that has a negative impact on the environment, the location of production and consumption. However, when submitting a “paper” declaration, you are also required to provide a copy of the declaration on a flash drive or other electronic media. That is, even if you have the right to report in paper format, you will still need to use the electronic service on the Rosprirodnadzor website to generate a declaration file. Then this declaration will need to be printed and the printed document and electronic file submitted to the Rosprirodnazdor authorities.

What if there are several objects?

If “negative” objects are located in different constituent entities of the Russian Federation, then separate declarations for each object must be submitted to the relevant bodies of Rosprirodnadzor. If the objects are located in one subject of the Russian Federation, then one declaration is submitted (clause 8 of the Procedure for submitting a declaration, approved by Order of the Ministry of Natural Resources dated January 9, 2017 No. 3).

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

Composition of the new declaration

The new form of declaration of payment for negative impact on the environment, approved by Order of the Ministry of Natural Resources dated January 9, 2017 No. 3, consists of the following sections:

  • title page of the declaration (includes general information about the company or individual entrepreneur);
  • the amount of fees to be paid to the budget (indicating the BCC);
  • Section 1. Calculation of the amount of payment for emissions of pollutants into the atmosphere 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 without exceeding the volume corresponding to the maximum permissible value of the combustion indicator;
  • Section 1.2. Calculation of the amount of payment for emissions of pollutants generated by flaring and (or) dispersion of associated petroleum gas when the volume corresponding to the maximum permissible value of the combustion indicator is exceeded;
  • 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 out the declaration: sample

As we have already said, organizations and individual entrepreneurs will not need to fill out the declaration “manually”. However, we believe it would be advisable to explain some aspects of filling out that should be paid attention to so that the declaration for 2016 can be checked and pass format and logical control the first time. So, when filling out, adhere to the following basic principles:

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

Title page

On the title page, indicate general information “about yourself.” In particular, you will need to indicate:

  • organizational and legal form;
  • name of the organization or full name of the entrepreneur;
  • telephone;
  • TIN and checkpoint;
  • Full name and signatures and

Calculation of the amount of fees to be included in the budget

Calculation of the amount to be contributed to the budget includes indicators of payment amounts, including by type, for each facility providing NVOS. This declaration sheet is filled out for each individual separately.

Line 010 indicates the code of the corresponding municipal entity - 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 of payment amounts, without taking into account the adjustment of their size. The indicator for this line must be formed as the sum of fees for all types of tax assessments and include in it payments calculated:

  • within the limits of permissible emissions standards (APE),
  • 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 disposal of production and consumption waste and above the specified limits.

The amount for line 020 in the table is determined in the following order: line 020 = line 021 + line 022 + line 023 + line 024
Lines 021, 022, 023 and 024 indicate the components of the payment amount by type of tax assessment, the values ​​of which are taken equal to the value of the indicator of the corresponding line:

  • page 021 = page 040;
  • page 022 = page 060;
  • page 023 = page 080;
  • page 024 = page 100.

Line 031 indicates OKTMO of stationary sources specified in Section 1 “Calculation of the amount of payment for a negative impact facility for emissions of pollutants into the air by stationary facilities.”

Line 040 reflects the amount of payment for emissions of pollutants into the air by stationary objects, calculated for each stationary source, without adjusting its size.

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

Line indicator 040 = total according to column 17 of Section 1, line “Total for stationary sources”.
Indicators in lines 041, 042 and 043 are decipherable to the amount reflected in line 040. All data for filling them out is contained in Section 1.

Line 041 reflects the amount of payment for emissions within the maximum permissible limit; the amount must correspond to the total in column 14 of Section 1, line “Total for stationary sources.”
Line 042 reflects the amount of payment for emissions within the limits for emissions of pollutants (VER), the amount must correspond to the total in column 15 of Section 1, line “Total for stationary sources.”

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

Other calculation lines are filled in similarly. Each indicator must correspond to the total calculation amounts for the corresponding section.

Lines 060 to 063 reflect the amounts of fees for emissions of pollutants during flaring and/or dispersion of associated petroleum gas, calculated for all stationary sources (flares, dispersion installations). This is what a sample calculation of the fee amount may look like, in which the BCC is indicated:

Section 1. Calculation of fees for emissions into atmospheric air

In section 1 of the declaration for 2016, it is necessary to provide a calculation of the amount of payment for emissions of pollutants into the air by stationary objects. The section must include data on each such object. When filling out Section 1, indicate:

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

Section 1.1

Section 1.1 must be completed by persons obligated to pay a fee, releasing harmful (pollutant) substances into the atmospheric air from sources of combustion and (or) dispersion of associated petroleum gas without exceeding the volume corresponding to the maximum permissible value of the combustion indicator and, in established cases, not using it , for each stationary source (flare, dispersion installation) of an object that has a negative impact on the environment. As part of the declaration, this section looks like this:

If the above combustion was not carried out, then there is no need to fill out this section and include it in the declaration for 2016.

Section 1.2

This section should be compiled by persons obligated to pay a fee, emitting pollutants into the atmospheric air during flaring and (or) dispersion of associated petroleum gas in volumes that exceed the maximum permissible value of the combustion index (Zpr), or in the absence of a measurement system and accounting for the volume of associated petroleum gas for each stationary source (flare unit, dispersion unit) of the facility that has a negative impact on the environment. This section consists of the following table:

Section 2. Calculation of fees for discharges into water bodies

Section 2 is filled out by a person obligated to pay a fee, who has discharges of waste and (or) drainage water into water bodies and their parts, for each discharge of an object that has a negative impact on the environment. When filling out section 2, indicate:

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

This section, without filling, looks like this:

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

Section 3 is completed for each negative impact facility and waste disposal facility separately. If the person obligated to pay the fee has an object that has a negative impact on the environment and a waste disposal facility that does not belong to the person obligated to pay the fee, this section is filled out separately for the object of negative impact and the waste disposal facility. It states:

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

Section 3.1: Municipal Solid Waste Disposal Fees

Section 3.1 is completed by regional operators for the management of municipal solid waste, operators for the management of municipal solid waste, carrying out burial activities, for each object of negative impact, waste disposal facility separately. When filling out Section 3, indicate:

  • category of an object that has a negative impact on the environment;
  • name of the object that has a negative impact on the environment;
  • code of an object that has a negative impact on the environment;
  • address of the location of the facility that has a negative impact on the environment;
  • information about the category of the facility (not filled in if the waste disposal facility does not belong to the person obligated to pay the fee);
  • name of the waste disposal facility;
  • registration number (if assigned) of the waste disposal facility;
  • 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).

Responsibility

Payments for negative environmental impact are not a tax. Therefore, it is impossible to fine under the Tax Code for late submission of a declaration on these payments. It is also impossible, for example, to block the current accounts of an organization or individual entrepreneur who has not submitted a declaration. However, it is possible to attract administrative charges from 20,000 to 80,000 rubles.

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

Thus, no later than March 10 of the year following the reporting year, 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 website of Rosprirodnadzor. However, if the person obligated to pay the fee does not have an electronic signature or access to the Internet, the fee declaration for 2016 can be submitted on paper (clauses 5-6 of the Procedure).

We would like to remind you that you are required to pay a fee for negative impact on the environment.
legal entities and individual entrepreneurs carrying out economic or other activities in Russia that have a negative impact on the environment. With the exception of legal entities and individual entrepreneurs carrying out economic or other activities exclusively at Category IV facilities that have minimal negative impact on the environment. In particular, payers of fees for the negative impact on the environment when disposing of waste, with the exception of solid municipal waste, are legal entities and individual entrepreneurs whose economic or other activities generated waste. When disposing of municipal solid waste, the payers of this fee are regional operators for the management of solid municipal waste, as well as operators for the management of municipal solid waste, carrying out activities for their disposal (Clause 1, Article 16.1 of the Federal Law of January 10, 2002 No. 7- Federal Law "

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