The article of Fontanka.ru concerning the complexity of producing the income statement contains the comments of the lawyer of S&K Vertical Daniil Kazin
Those who either want or do not want to produce the income statement have less than a month left. The tax inspectorates are traditionally full of lined up queues – people as usual shelve this troublesome procedure to the uttermost, doubting the reliability of posting. The afflictions of the declarants was felt on the Fontanka reporter’s own back.
The reporter did not manage to meet her engagements before the State and to produce the income statement to the tax inspectorate within a day. As it turned out, first one needs to “change the Individual Taxpayer Identification Number (ITIN)”. The consultant of the tax inspectorate spoke just so and the argument that this number is given to the individual once and for all was wrathfully rejected. Thanks to the Internet and the control dial up to the information office of the inspectorate it became clear that not the ITIN itself, but the certificate of it should be changed. Such a change entails the expenses amounting to 5 rubles (for the headed certificate-paper) and two lost days – one for producing the declaration to change the certificate and the second for obtaining the new certificate, the lack of which would cause the refusal in receipt of the income statement.
“One should not mix up two categories – the ITIN and the certificate of registration in the tax authority” – explains Nikolay Vilchur, the director of the international consulting company Vilchur and partners. “ITIN, roughly speaking, is a number consisting of 12 digits. This number is not a subject to any alterations either after the change of domicile or after the change of the last name”.
“Concerning the change of the certificate of registration in the tax authority: neither Russian Tax Code nor the statutory acts contain the legal norms obliging the tax payer to produce the declaration of changes in the personal data. The authorities conducting the registration of the individuals at their domicile or the registration of the acts of civil status have to inform the tax authorities of the correspondent facts themselves.
Thus, there is no obligation to produce the above mentioned declaration of changes. To the contrary, for the convenience of the both parties one may produce such a declaration on one’s own – for example, in order to avoid the issues regarding the discrepancy in the data of the certificate and the identity documents”.
Daniil Kazin, the lawyer of the law firm S&K Vertical agrees with him: “The ITIN itself should not be the subject to alterations. However, in case the certificate was issued as of the old form (the new one was approved in 2006) and the individual was registered in the tax authority in accordance to the new domicile, than such a certificate should be changed”.