Taxpayers, attention!

Questions

Answers

І. General questions about the Order № 296

1. Should information be duplicated in report forms 1-VP, 1-OP regarding types of products/goods, if the manufacturer, in addition to manufacturing certain type of products/goods, also receives this type of products/goods from other business entities for sale within the framework of wholesale activity?

Paragraph 1 Section І of Procedure for filling out report form № 1-OP (hereinafter – Procedure № 1-OP) stipulates that the specified report is submitted by licensees who have received licenses for the wholesale of ethyl alcohol (including bioethanol), alcohol distillates, alcoholic beverages and tobacco products, liquids used in electronic cigarettes, and carry out such activities and/or export, import of the specified products, except for manufacturers of the specified products/goods (hereinafter – products/goods).

Therefore, licensees – manufacturers submit only the Report form № 1-VP, in which (according to Paragraph 1 Section III of the Procedure for filling out report form № 1-VP (hereinafter – Procedure № 1-VP) regarding filling out Section II "Circulation volumes of products ready for sale to the final consumer") in Section II information on products/goods, volume of which was purchased/received from other business entities, is indicated for sale within the framework of wholesale activity.

Therefore, duplication of information in report forms 1-VP, 1-OP regarding types of products/goods, if the manufacturer, in addition to manufacturing certain type of products/goods, also receives this type of products/goods from other business entities for sale within the framework of wholesale activity, does not occur.

2. Do the new forms 1-VP, 1-OP provide for submission of a clarifying report for previous periods when reporting was submitted according to forms 1-OA, 1-OT, 2-RS?

In connection with the entry into force of Order № 296 on October 1, 2024 and loss of validity of previous report forms approved by Order№ 493, starting from October 2024, reports are submitted according to the new forms, including clarified reports for previous reporting periods, including if reporting to be clarified was submitted according to the forms approved by Order № 49^[3]  (in particular, according to the report form 1-VP when clarifying reports submitted according to the form 1-RS, 2-RS, 3-RS).

3. How to indicate registration number of license, if the business entity has several licenses for the wholesale of alcoholic beverages and tobacco products?

In line 09 of the general parts of report forms 1-VP and 1-OP, which has a text format, the business entity has opportunity to indicate all the licenses it has.

ІІ. Questions regarding filling out the report form № 1-OP

1. How many digits after the decimal point filling out volumes in dal?

Before making changes to the digital field, graph for indicating volume of products in the electronic report forms 1-VP and 1-OP, which provide for reflection of 6 decimal places or an integer, in the current electronic forms, the digital field provides for reflection of 2 decimal places or an integer. These forms are posted on web portal of the State Tax Service in section "Electronic reporting > To taxpayers on electronic reporting > Information and analytical support > Register of electronic document forms" (https://tax.gov.ua/elektronna-zvitnist/platnikam-podatkiv-pro/informatsiyno-analitichne-za/reestr-elektronnih-form-po/).

2. Section 1 of the Report: In case of returning products/goods, their volume is marked with a sign "(-)". Is the return to be allocated separately or made in the total volume?

Procedure for filling out form № 1-OP stipulates that in case of returning products/goods, their volume is indicated with a sign "(-)", at the same time filling out section I "Volumes of purchase and sale (including import and/or export) of products/goods" provision is made for the following:

in columns 5-8 – total volume of purchase/return of products/goods by the business entity for the entire reporting month (Paragraphs 3-6 Section II of Order № 1-OP);

in column 9 – total volume of sale/return of sold products/goods for the reporting month (Paragraph 7 Part II of Order № 1-OP).

As follows, the return indicator reduces volume of purchase (columns 5 – 8) / sale (column 9) and is indicated by the total volume, and in case of excess of the return volume over the volume of purchase/sale for reporting month, the indicator is indicated with a sign "(-)".

3. Section 4 of the Report:

- What does a Sign of transfer/receipt for safekeeping mean? If own product balances of the business entity that submits the report are stored in warehouses of logistics company, then is it needed to put the digital code of a sign "2" and in Paragraph 3 indicate code from the only state register code of enterprises and organizations of Ukraine of logistics provider?

If the remains are stored in a storage place of warehouse of logistics provider and the place is registered in the Unified State Register, then this is equated to composition of the business entity that submits the report, and in this case is it necessary to put the digital code of a sign "1" and in in Paragraph 3 indicate code from the only state register code of enterprises and organizations of Ukraine?

If own product balances of the business entity that submits the report are stored in warehouses of logistics company, then in column 2 Section IV of the report form1-OP, the digital code of a sign "2" must be entered upon transfer, and in column 3 – registration data of logistics provider – custodian.

Business entity that submits the report, receiving products for storage, reflects volume of received products and in column 2 Section IV of the report form 1-OP notes the digital code of a sign "1" upon receipt, and in column 3 –  the consignee's registration data.

4. Is Report for September submitted according to the new form in October?

Yes. Answer to the question is set out in Paragraph 1 of Section I.

5. Will sub-codes (including) be duplicated in codes? For example, 37-39, 42-46, 60-64

Yes. For example, information regarding product codes 38 "including grape table wines" and 39 "including fortified grape wines" is reflected separately (in separate lines), and their volumes should also be simultaneously reflected under code 37 "Grape wines".

6. Determining the product code, are payers guided by the categories according to the Law on geographical indications and Article 61 of the Law on circulation?

Filling out the report forms, it is necessary to indicate Codes of products/goods, which are given in column 1 Section I of Codes, measurement units and types of products/goods, approved by Order № 296, which correspond to relevant codes of the Ukrainian classification of the foreign economic activity products and product types.

7. How to calculate dal of the anhydrous ethyl alcohol?

Anhydrous ethyl alcohol is conventionally 100 percent ethyl alcohol. To calculate amount of anhydrous ethyl alcohol in product, the following parameters must be used:

total volume of product in deciliters (hereinafter – dal);

volume number of pure ethyl alcohol in 100 volumes of the product.

Example.

To calculate volume in dal of anhydrous alcohol in the alcoholic beverage, it is necessary to divide volume of alcoholic beverage in dal by 100 and multiply by the number of volumes of pure ethyl alcohol in 100 volumes of alcoholic beverage.

Vodka with ethyl  alcohol concentration of 42 vol.%:

Divide 100 dal of vodka by 100 and multiply by the number of volume of pure ethyl alcohol in 100 volumes of vodka – 100 dal / 100 x 42% = 42 dal of the anhydrous ethyl alcohol.

8. Is it necessary to specify both measurement units indicated in the table (dal and dal of the anhydrous ethyl alcohol) or one of the indicated ones?

Yes. It is necessary to indicate in separate lines both measurement units indicated in the table (dal and dal of the anhydrous ethyl alcohol).

9. Do all balances or only wholesale have to be reflected in the first Section?

All volumes of product balances, except for those transferred to the own retail network, are indicated in Section I.

10. Is reflection of movements between wholesale and retail warehouses introduced? (transferred/returned to/from the retail location(s);)

Yes. Circulation of products, in particular, information about products/goods transferred to places of the retail sale, including those transferred to the own retail network is reflected.

11. Is it necessary to fill in column: Column 12 indicates the following explanations for columns 4-11 (if available): is the type of customs regime indicated upon import/export of products/goods?

Yes. In case of import/export of products/goods, the type of customs regime must be indicated.

12. Where to get individual number of the activity place? "Individual number of the storage place in the Unified state register of storage places and activity place (according to form 20-OPP) on the basis of the corresponding license"? 

Column 1 Section IV of the report form indicates individual number of the storage place in the Unified state register of storage places and activity place.

ІІІ. Questions regarding filling out the form № 1-VP

1. How to reflect in the report column 5 "Balance at the beginning of reporting period" of Section I "Volumes of production and circulation (including import and/or export) of products/goods" data on the volume of products/goods used as raw materials for beer production, if the type code of products/goods is missing (e.g., barley, malt, wort, hops, yeast, coffee, berries, fruits, etc.) or different from the balance code of manufactured products at the beginning of reporting period, according to the Codes approved by the Order № 296 as of 18.06.2024?

In the reports, as raw materials for manufacture of products, the raw materials (which are used for manufacture of products) are indicated in the Codes, measurement units and types of products/goods approved by Order № 296 and regulated by the Law № 3817 (for example, manufacturers of alcoholic beverages indicate alcohol or wine materials, manufacturers of tobacco products – tobacco raw materials).

Types of products/goods that are used as the raw materials and whose codes are not listed in the Codes, measurement units and types of products/goods approved by the Order № 296 and not regulated by the Law № 3817 are not reflected in the reports.   

2. Is it necessary to indicate in column 7 "Total" and, accordingly, columns 8-9 of Section I "Volumes of production and circulation (including import and/or export) of products/goods" receipt/return (-) volume of products/goods received by the manufacturer as the raw material for production of beer, but such raw material does not contain ethyl alcohol or wine materials (eg. barley, barley malt, hops, yeast, wort)?

Answer to the question is given in Paragraph 1 of Section III.

3. Is it necessary to indicate in column 16 of Section "Volumes of production and circulation (including import and/or export) of products/goods" amount of use (expenditure) of products produced/received as the raw materials for production of other products, if such raw materials do not contain ethyl alcohol or wine materials, (eg. barley, barley malt, hops, yeast, wort)?

Answer to the question is given in Paragraph 1 of Section III.

4. What information must be specified in Sections II "Circulation volumes of products ready for sale to the final consumer" and III "Volumes of receipt and shipment of products/goods", if the manufacturer is involved in the wholesale of alcoholic beverages and tobacco products of those types of products/goods that such business entity does not manufacture?

Filling out the report form, product manufacturers who are simultaneously involved in wholesale of products (regardless of the types of products/goods manufactured and types of products/goods purchased/received from other business entities) indicate:

in Section I – information on the volumes of receipts/returns (including as the raw materials), production and circulation of manufactured products (Section II of the Procedure for filling out Section I "Volumes of production and circulation (including import and/or export) of products/goods" of the Order № 1-VP);

in Section II – information on products/goods, volume of which was purchased/received from other business entities (Section III of the Procedure for filling out Section II "Circulation volumes of products ready for sale to the final consumer" of the Procedure № 1-VP); 

in Section ІІІ – information about received and shipped products/goods, namely:

in the part "Products/goods of Columns 7-15 of Section I" shipped self-manufactured products;

in the part "Goods of Columns 5-9 of Section II" shipped products, volume of which was purchased/received from other business entities (Section IV of the Procedure for filling out Section III "Volumes of receipt and shipment of products/goods" of the Procedure № 1-VP).

5. How should information be specified in Sections II "Circulation volumes of products ready for sale to the final consumer" and III "Volumes of receipt and shipment of products/goods", if the manufacturer, in addition to manufacturing certain type of products/goods, also receives this type of products/goods from other business entities?

Answer to the question is given in Paragraph 4 of Section III.