Источник картинки: http://topfranchise.ru/
Разовый платеж, недра, пользование
Как учитывать разовый платеж за пользование недрами
24.05.2017
Арбитражный суд Московского округа по делу № А40-98153/16 поддержал позицию налогового органа о том, что разовый платеж за пользование недрами списывается в расходы равномерно в течение двух лет с момента получения лицензии.В 2013 году по итогам аукциона на получение права пользования недрами налогоплательщик зарегистрировал соответствующую лицензию, по условиям которой компания должна была уплатить разовый платеж за пользование недрами.Этот платеж налогоплательщик единовременно включил в состав косвенных расходов в декларацию по налогу на прибыль организаций за 2013 год. В связи с этим была занижена база по налогу на прибыль организаций – компания налог не уплатила.Так как лицензия была получена до оплаты права пользования недрами, налогоплательщик посчитал, что разовый платеж не связан с её получением, а значит учет такого платежа в качестве расходов производится единовременно.По мнению инспекции, разовый платеж за пользование недрами является одним из условий аукциона для получения лицензии, то есть расходы в данном случае непосредственно связаны с приобретением лицензии и должны учитываться в составе расходов не единовременно, а равномерно в течение двух лет.Налогоплательщик, не согласившись с инспекцией, обратился в суд. Суды трех инстанций, отказывая в удовлетворении требований налогоплательщика, признали выводы инспекции обоснованными.
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Эта статья оказалась исключительно информативной и понятной. Автор представил сложные концепции и теории в простой и доступной форме. Я нашел ее очень полезной и вдохновляющей!
Я прочитал эту статью с большим удовольствием! Она написана ясно и доступно, несмотря на сложность темы. Большое спасибо автору за то, что делает сложные понятия понятными для всех.
Автор не вмешивается в читателей, а предоставляет им возможность самостоятельно оценить представленную информацию.
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Я просто восхищен этой статьей! Автор предоставил глубокий анализ темы и подкрепил его примерами и исследованиями. Это помогло мне лучше понять предмет и расширить свои знания. Браво!
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Я просто восхищен этой статьей! Автор предоставил глубокий анализ темы и подкрепил его примерами и исследованиями. Это помогло мне лучше понять предмет и расширить свои знания. Браво!
Это помогает читателям самостоятельно разобраться в сложной теме и сформировать собственное мнение.
Спасибо за эту статью! Она превзошла мои ожидания. Информация была представлена кратко и ясно, и я оставил эту статью с более глубоким пониманием темы. Отличная работа!
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Автор предлагает рациональные и аргументированные выводы на основе представленных фактов.
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Автор предоставляет читателю возможность взглянуть на проблему с разных сторон.
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