Евгений Шелест
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ФНС России разослала нижестоящим налоговым органам, осуществляющим администрирование земельного налога, для учета в работе письмо со ссылкой на Определение Конституционного Суда Российской Федерации от 8 ноября № 2725-О (письмо ФНС России от 17 декабря 2018 г. № БС-4-21/24467@ «О налогообложении дачных земельных участков коммерческой организации»). Согласно данному документу налогоплательщик может быть освобожден от начисления пени и штрафа, если он следовал разъяснениям органов по вопросам, относящимся к их компетенции.
Налоговая инспекция, проведя выездную налоговую проверку, доначислила юрлицу налоги, пени, штрафы, в том числе и по земельному налогу. Общество обжаловало решение налогового органа в суд, полагая, что выполнение письменных разъяснений о порядке исчисления и уплате налога, данных финансовым органом местного самоуправления, в любом случае освобождает налогоплательщика от начисления пени и штрафа по этому налогу на основании п. 8 ст. 75, подп. 3 п. 1 ст. 111 Налогового кодекса. По мнению юрлица, из разъяснений следовало, что принадлежащие ему земельные участки с разрешенным видом использования «для дачного хозяйства» («для дачного строительства») облагаются по пониженной ставке земельного налога 0,3% (абз. 4 подп. 1 п. 1 ст. 394 НК РФ).
Нужно ли подавать декларацию, если в ЕГРН нет сведений о кадастровой стоимости земли? Узнайте из материала «Декларация по земельному налогу» в «Энциклопедии решений. Налоги и взносы» интернет-версии системы ГАРАНТ. Получите полный доступ на 3 дня бесплатно!
КС РФ отметил, что финансовые органы муниципальных образований могут давать только разъяснения относительно нормативных правовых актов соответствующего уровня. Но не касаясь вопросов, которые отражены в НК РФ и законодательстве субъекта Федерации. Органы местного самоуправления могут устанавливать размер налоговой ставки земельного налога, в том числе в отношении земельных участков, приобретенных (предоставленных) для личного подсобного хозяйства, животноводства или огородничества, садоводства, дачного хозяйства. Однако указанные органы не вправе определять условия отнесения тех или иных земельных участков к указанной категории и разъяснять, какие участки считаются приобретенными (предоставленными) для дачного хозяйства. При этом пониженная ставка, предусмотренная подп. 1 п. 1 ст. 394 НК РФ может применяться только физлицами и некоммерческими организациями, а на коммерческие она не распространяется. Это подтверждается судебной практикой.
КС РФ отказал организации в принятии жалобы к рассмотрению.
Russian
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Автор явно старается сохранить нейтральность и представить множество точек зрения на данную тему.
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Очень хорошо исследованная статья! Она содержит много подробностей и является надежным источником информации. Я оцениваю автора за его тщательную работу и приветствую его старания в предоставлении читателям качественного контента.
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Мне понравилась балансировка между теорией и практикой в статье.
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Мне понравилась объективность автора и его способность представить информацию без предвзятости.
Приятно видеть объективный подход и анализ проблемы без сильного влияния субъективных факторов.
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Эта статья — источник ценной информации! Я оцениваю глубину исследования и разнообразие рассматриваемых аспектов. Она действительно расширила мои знания и помогла мне лучше понять тему. Большое спасибо автору за такую качественную работу!
Статья представляет анализ различных точек зрения на проблему.
Статья содержит актуальную статистику, что помогает оценить масштаб проблемы.
Автор статьи представляет сведения, опираясь на факты и экспертные мнения.
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Автор представляет информацию в организованной и последовательной форме, что erleichtert das Verständnis.
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Мне понравилось разнообразие источников, использованных автором для подкрепления своих утверждений.
Автор предоставляет дополнительные ресурсы для тех, кто хочет углубиться в изучение темы.
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