AD ALTA
JOURNAL OF INTERDISCIPLINARY RESEARCH
organizations (including banking), as well as other business
entities, also transfer insurance contributions to off-budget social
funds (Pension Fund, Social and Health Insurance Fund). In the
Russian Federation, insurance contributions to off-budget social
funds, although they increase the tax burden, are not included in
the general taxation system.
The specifics of the financial and economic activities of banking
organizations, the list of their operations, transactions, services
provided determine the specifics of the taxation method for this
category of taxpayers. In particular, in accordance with the
current Russian legislation, in the methodological aspects of
calculating and levying taxes on the banking sector of the
economy, such taxes as income tax and VAT have specific
characteristics. The rest of the taxes are paid by banking
organizations in accordance with the generally established
procedure.
The key tax in the taxation system of credit institutions in the
Russian Federation is income tax. Since 1.01.2002 in accordance
with Chapter 25 of the Tax Code, Russia uses an updated
methodology for calculating and paying corporate income tax.
Moreover, this methodology characterizes the general principles
of taxation of all payers, as well as the peculiarities of taxation of
certain categories, including banks. In Russia, with the adoption
and implementation of Chapter 25 of the Tax Code of the
Russian Federation, the existing tax exemptions on corporate
income were cancelled and a single tax rate was established for
all business entities, including banks.
The reform of the taxation system of organizations carried out in
the Russian Federation after 2000, in general, contributed to a
decrease in the tax burden on credit organizations, in connection
with the introduction of Chapter 25 of the Tax Code of the
Russian Federation (due to a decrease in the base rate of
corporate income tax, from 43% to 24% and then up to 20%).
Until 2002, banking, brokerage and insurance organizations in
the Russian Federation paid income tax at a rate of 43%, while
for other segments of the economy the income tax rate was 35%.
At present, credit institutions pay income tax on their profits at
the basic, generally established rate of 20%.
In addition to the general income the same as for all taxpayers,
the income of “the bank which is subject to profit taxation
includes: interest from the placement of funds by the bank,
provision of loans and credits; fees for opening and maintaining
a customer bank account; payment for the collection of cash,
bills, payment and settlement documents and cash services for
clients; income from foreign exchange transactions, as well as
from the purchase and sale of precious stones and precious
metals; other income related to banking” [17].
Thus, the peculiarity of banks’ incomes is that the main part of
them belongs to incomes that other profit taxpayers relate to
other taxes and are independent in terms of taxation as part of
non-operating income. For banks, these incomes are directly
related to the sale of their specific services. It should also be
noted that the costs common to all taxpayers have certain
characteristics for commercial banks. For example, in
accordance with the provisions of Article 260 of the Tax Code of
the Russian Federation, banks are classified as taxpayers, for
whom the amount of repair costs is regulated. In Article 264 of
the Tax Code of the Russian Federation, expenses for
maintaining their own security service to perform the functions
of protecting banks and business operations and saving assets,
etc. are allocated.
Another tax paid by banking organizations is VAT. There are
three VAT rates in the Russian Federation (0%, 10% -
preferential, and 20% - basic). Banking operations, with the
exception of cash collection operations, are not subject to value
added tax. The provision of a loan in cash is also exempt from
the VAT. At the same time, all other banking transactions and
services are subject to taxation at the basic rate of 20%.
It should be noted that although transactions that are and are not
subject to the VAT are described in Chapter 21 of the Tax Code
of the Russian Federation, in practice it is very difficult to
separate a taxable transaction from the one which is not subject
to the value added tax. In addition, there is no special tax in the
RF that reflects the specifics of banks' activities. At the same
time, as it was noted above, they pay similar taxes as other
business entities.
3 Results
As the analysis and assessment of the methodology for
calculating and levying income tax showed, in the Russian
Federation, in general, there is a low income tax rate for the
banking sector of the economy. However, despite this, it should
be noted that the current taxation mechanism of banking
organizations in the RF has a number of difficulties. This applies
both to the problems of interpretation of the relevant chapters of
the Tax Code, regulating the procedure of paying corporate
income tax and value added tax, and to the absence of incentives
for banks lending science-intensive industries and the real sector
of the economy. One of the difficulties in calculating the tax on
profit of organizations is the task of attributing income or
expenses to the sale of banking services or non-operating
expenses, which directly distorts the real financial result of
banks’ operations. It should also be noted that in world practice,
as a rule, progressive taxation is applied to excess profits of
credit institutions (with an increase in taxable profit, the tax rate
rises).
In Russia, unlike in many foreign countries, there is no
progression in the method of calculating and levying income tax.
Let us analyse the indicators of the structure and dynamics of
taxes paid to the budget using the example of one of the largest
banks in the Russian Federation, public joint stock company
(PJSC) Sberbank of Russia for 2016-2018. At present, PJSC
Sberbank of Russia is the leader of the Russian banking system
and, accordingly, is a fairly stable and large payer of corporate
income tax. One should begin the analysis of the timeliness and
completeness of paying taxes to the budget with determining the
tax burden, that is, the ratio of taxes paid during the tax period to
the amount of revenue [18]. In the case that the tax burden is
calculated according to the method recommended by the Federal
Tax Service of Russia (tax burden = S paid taxes × 100%/S of
revenue per year, excluding VAT), then the tax burden of PJSC
Sberbank of Russia as of 01.01.2019 amounts to 10.6%, while
on average in other sectors of the Russian economy (including
the real sector) - 22.8%. Table 1 presents data on the amount of
taxes paid by Sberbank
of Russia, according to its annual
reports.
The data in Table 1 shows that there was an increase in the
expenses of paying taxes in 2018 compared to 2016 by 103,807
million rubbles (117.3%). Analyzing the indicators in Table 1, it
can be noted that most of the bank's tax expenses (excluding
insurance contributions to extra-budgetary social funds) fall on
income tax (in 2018, it accounted for 83.5% of the bank's tax
expenses). At the same time, in the general structure for the
period from 2016-2018, this tax tends to grow, while other taxes
and fees tend to decrease. In particular, in 2018 compared to
2016, there was an increase in expenses of PJSC Sberbank of
Russia for the payment of income tax by more than 4 times.
Table 1. Changes rate in the expenses of Sberbank of Russia for
the payment of taxes by their types for 2016-2018 (million
roubles,%)*
No.
T
ype
of
T
ax
2016
2017
2018
C
ha
nge
s,
mln
.
rub
. (
+
-)
C
ha
nge
s
R
at
e,
in
%
2018/
2016
Total expenses
of the bank for
the payment of
taxes,
including:
88513
149605
192320
100380
7
117,3
1.
Profit Tax
53412
120418
165039
111627
482,4
2.
VAT
25560
19068
21180
-4380
-17,1
- 250 -