1. THE SUBJECT OF THE AGREEMENT
1.1. Under this agreement, the Lender provides the Borrower with a loan in the amount of rubles, and the Borrower undertakes to repay the Lender the loan amount and pay accrued interest for using the loan in accordance with the terms and conditions established by this agreement.
1.2. Interest rate for this contract is % per annum.
1.3. Interest for using the Loan is accrued based on the actual number of calendar days of using the loan, while the actual number of calendar days in a year (365 or 366) is taken as the base, and the number of settlement days in a month corresponds to the actual number of calendar days in a month.
1.4. The period for accruing interest for the use of the loan begins on the day the Lender actually issues the loan amount to the Borrower or transfers the loan amount to the specified account of the Borrower and ends on the day the Loan is returned to the Lender. The Borrower undertakes to pay the accrued interest for the use of the loan on a monthly basis, not later than the last business day of the month.
2. TERMS OF ISSUANCE AND REPAYMENT OF THE LOAN
2.1. The loan is provided on the basis of this agreement.
2.2. The loan is provided by issuing the loan amount from the Lender's cash desk or transferring the loan amount to the specified account of the Borrower.
2.3. The Borrower has the right to repay the debt under the Loan and (or) interest for using it by depositing cash to the Lender's cash desk or transferring to non-cash form amounts owed to the settlement account of the Lender;
3. RIGHTS AND OBLIGATIONS OF THE PARTIES
3.1. The Lender undertakes to ensure the provision of a loan within working days from the date of signing by the parties of this agreement.
3.2. The Lender undertakes to provide the Borrower with a loan on the terms of this Agreement.
3.3. The Lender undertakes to advise the Borrower on all issues related to the execution of this Agreement.
3.4. The Borrower undertakes to repay the loan and pay interest for its use within the terms specified in this Agreement and in full.
4. REPAYMENT OF DEBT
4.1. The Borrower repays the Loan in accordance with the terms established by this Agreement.
4.2. The Borrower has the right to repay the Loan ahead of schedule.
4.3. In the event that the Borrower makes the final early repayment of the Loan, the Borrower shall, simultaneously with the repayment of the principal debt under the Loan, repay all accrued interest.
4.4. The date of repayment of any payments is the date of actual receipt of funds to the relevant account (accounts) of the Lender or the date of payment of the amount of the debt to the Lender's cash desk.
4.5. If the Borrower misses the maturity of any payments, the outstanding term debt is treated as overdue debt with interest accruing at the Higher Interest Rate from the date of its occurrence.
4.6. Overdue debt is considered urgent (primary) to be repaid at any time.
4.7. The repayment of the debt to the Lender is made in the following order:
- penalty fee;
- overdue interest on the Loan;
- overdue principal debt;
- urgent interest on the Loan;
- term debt principal.
5. PROCEDURE FOR SECURING THE OBLIGATIONS OF THE BORROWER
5.1. In order to ensure the repayment of the Loan, the Parties undertake to conclude Collateral Agreements and provide for other security measures.
5.2. Interim measures include: pledge of real estate; pledge Vehicle; pledge of claims, including securities; granting by the Borrower to the Lender the right to extrajudicial foreclosure directly on the subject of pledge provided for in the Collateral Agreements; guarantee; bank guarantee; retention of collateral and funds belonging to the Borrower; other measures agreed by the Parties.
5.3. The Lender shall have the right to choose the methods of securing obligations under this Agreement and their assessment.
5.4. The collateral for the Loan, taking into account liquidity, must cover the principal and accrued interest. In case of increase term debt or the occurrence of arrears, the Borrower is obliged to increase the collateral to the required size and quality.
5.5. The Security Agreements signed in pursuance of this Agreement are valid in conjunction with it and are inseparable from it. Simultaneously with the signing of this Agreement, the Guarantee Agreement No. dated "" 2020 and (or) the Guarantee Agreement No. dated "" 2020 are concluded to secure it. In the event of an increase in collateral, newly concluded contracts are indicated in the Agreements.
5.6. In case of deterioration of the physical qualities of the subject of pledge or other loss of liquid qualities by it, like any other provisional measure, the Lender has the right to demand a replacement of the method of collateral and choose it at its own discretion.
6. TERM OF THE CONTRACT
6.1. The term for using the loan is days from the date of the actual issuance by the Lender of the loan amount to the Borrower or the transfer of the loan amount to the specified account of the Borrower. The Borrower undertakes to make the final settlement on payment of the loan amount and accrued interest for the use of the loan to the Lender before ""2020.6.2. This agreement comes into force from the moment the Lender actually issues the loan amount to the Borrower or transfers the loan amount to the specified account of the Borrower and is valid until its full repayment and payment of accrued interest for using it.
7. EARLY PERFORMANCE OF OBLIGATIONS
7.1. In case of early repayment of the loan, the Borrower must notify the Lender of the early repayment no later than working days in advance.
7.2. In case of early repayment of the loan, the interest for using the loan is paid by the Borrower for the actual term of using the loan.
8. RESPONSIBILITY OF THE PARTIES
8.1. If the Borrower violates the deadlines established for making the next payment for the repayment of the loan and paying the accrued interest for using it, the Lender has the right to terminate the agreement and demand from the Borrower early repayment of the loan amount and payment of interest due for using the loan.
8.2. From the moment the overdue debt on the Loan arises, the Borrower shall pay the Lender increased interest for the use of the overdue Loan in the amount of % per annum (hereinafter referred to as the increased Interest).
8.3. Increased Interest is accrued on the amount of the overdue Loan from the date of occurrence of the delay until the day of full repayment of the overdue Loan.
8.4. At late payment Interest shall be paid by the Borrower to the Lender irrespective of the payment of Interest stipulated in Clause 1.2. of this Agreement, the Penalty in the amount of %, accrued on the amount of the overdue payment of Interest for each day of delay, from the date following the date of occurrence of the delay to the date of its repayment (inclusive).
8.5. The Borrower's obligations to repay the Loan and pay Interest (including increased interest) are considered to be fulfilled in full from the date of receipt of funds to the current account and (or) to the Lender's cash desk.
8.6. With the Lender's consent, the Borrower's obligations to repay the Loan and pay Interest may be fulfilled in other ways that do not contradict the current legislation of the Russian Federation.
8.7. In the event that the Borrower violated the deadline set for making the next payment for the repayment of the loan and paying accrued interest for using it, and the Lender did not exercise the right provided for in clause 7.1. of this agreement, the Borrower is obliged to pay the Lender interest for the use of the loan, accrued according to the rules provided for in paragraphs 1.2-1.5 of this agreement for the entire actual period of using the loan.
8.8. The Borrower shall reimburse the Lender for all costs associated with the collection of debt under this Agreement.
8.9. The Borrower's refusal to repay the debt to repay the loan and pay the accrued interest for using it, or the violation of the terms of repayment of the Borrower's debt established by this Agreement, serves as a basis for limiting its possibilities for further borrowing.
9. FINAL PROVISIONS
9.1. In everything that is not reflected in this agreement, the parties will be guided by the current legislation of the Russian Federation.
9.2. The date of fulfillment of obligations under the agreement by the Borrower is the date of full repayment of the debt to repay the loan and pay accrued interest for its use.
9.3. All disputes and disagreements arising during the validity of this agreement, the parties will try to resolve through negotiations.
9.4. If the dispute is not settled, then it is subject to resolution in the manner prescribed by the current legislation of the Russian Federation.
9.5. Changes and additions to this Agreement are carried out in the manner prescribed by applicable law.
9.6. This Agreement is made in two copies of equal legal force, one for each party.
10. LEGAL ADDRESSES AND BANK DETAILS OF THE PARTIES
Lender
Borrower Jur. address: Postal address: TIN: KPP: Bank: Settlement/account: Corr./account: BIC:
Loan and interest
Clause 1 of Article 807 of the Civil Code of the Russian Federation establishes that the lender, when concluding a loan agreement, must transfer money or things to the borrower, which he must subsequently return. Thus, it follows from the provisions of this paragraph that the legally significant conditions of a loan transaction are questions about the subject of the loan (money or things) and the need to return the property borrowed.
At the same time, about the need to pay compensation to the lender for the use of his property, that is, the payment of interest on loan agreement,V Paragraph 1 of Article 807 of the Civil Code of the Russian Federation is out of the question. Consequently, a loan transaction, in accordance with the requirements of Article 432 of the Civil Code of the Russian Federation, will be considered concluded, even if the issue of interest is not settled by the parties in the text of the agreement.
This conclusion is directly confirmed by the provision of paragraph 1 of Article 809 of the Civil Code of the Russian Federation, which determines that there may be no indication of the need to pay interest in the text of the agreement.
However, the practice of relations between economic entities gives key importance to the issues of determining the amount of interest under a loan agreement and their payment, since the main goal of a commercial organization is to make a profit. Consequently, all the subtleties of determining the amount and procedure for paying interest should be carefully reflected in the text of the agreement between legal entities.
Interest for using a loan under article 809 of the Civil Code of the Russian Federation
Paragraph 1 of Article 809 of the Civil Code of the Russian Federation indicates that the lender, having transferred the money to the borrower, acquires the right to receive interest for the use of them, unless otherwise specified in the agreement of the parties. Thus, a cash loan for an organization is assumed to be paid in all cases where the text of the agreement does not expressly state that it is interest-free.
The absence of an agreement on interest in the text of the agreement does not automatically make it interest-free, as expressly stated in Article 809 of the Civil Code of the Russian Federation. In this situation, the procedure for determining them, indicated in paragraphs 1 and 2 of Article 809 of the Civil Code of the Russian Federation, will only apply. According to the provisions of these paragraphs, the borrower will be required to pay interest each month of using the lender's funds in an amount determined on the basis of key rate Central Bank of the Russian Federation at the time of transfer of the payment or part of it. However, if the participants in the transaction are individuals or individual entrepreneurs, and the loan amount is less than 100 thousand rubles, then the agreement is considered interest-free, unless it expressly states otherwise.
However, it is worth mentioning a special case when the subject of the loan is not money, but things. In such a situation, in accordance with paragraph 4 of Article 809 of the Civil Code of the Russian Federation, in the absence of an agreement between the parties on the issue of interest, the contract is automatically assumed to be interest-free.
Interest on early repayment of a loan
Articles 809 and 810 of the Civil Code of the Russian Federation closely associate with the interest under the contract another key (but legally insignificant) condition of the agreement - the maturity of the debt. According to paragraph 1 of Article 810 of the Civil Code, a loan can be urgent (with a fixed repayment date) or unlimited (in this case, the lender should notify the borrower of the debt repayment date 1 month in advance or at another time specified in the agreement).
It is important to remember that depending on the need to pay interest, the possibility of repaying the loan ahead of schedule will be determined. So, according to article 810 of the Civil Code of the Russian Federation, if the loan is interest-free, then the borrower has the right to return it ahead of schedule at will.
At the same time, if a transaction between organizations involves the payment of interest, early repayment of the debt is possible only with the approval of the lender. Such a limitation is determined by the observance of his financial interests, since in case of early repayment of the loan, he will receive a smaller amount of compensation for the use of his money than he expected at the conclusion of the transaction. If an interest-bearing loan is granted to an individual, for personal needs, he can return it, having previously notified the lender of this 30 days before the return.
Clause 4 of Article 809 of the Civil Code of the Russian Federation states that in case of early repayment of a loan, the borrower is required to pay interest up to and including the date of actual repayment of the loan. Thus, the possibility of repaying an interest-bearing loan ahead of schedule will be determined solely by the financial interest of the lender, who has the right to give permission for early repayment, thereby not receiving part of the expected income, or not to give such permission in order to receive the entire amount of interest under the agreement.
Maximum interest rate, minimum interest rate, change (decrease or increase) in the loan fee
When drawing up a loan agreement for an organization, it must be remembered that the norms of the Civil Code of the Russian Federation do not determine the maximum amount of interest for the use of the lender's funds.
Don't know your rights?
For reference: in judicial practice a position has developed, the purpose of which is to create conditions for establishing fair and non-destructive interest on credit and loan transactions. As an example, we can cite the ruling of the collegium of the Supreme Court of the Russian Federation dated March 29, 2016 in case No. 83-KG 16-2, which states that a loan transaction, despite the principle of freedom of contract provided for in paragraph 1 of Article 421 of the Civil Code of the Russian Federation, should not be clearly burdensome for the borrower.
It should also be noted that information on size limit percent, published by the Central Bank of the Russian Federation on a quarterly basis, is also not directly related to organizations due to the operation of Part 11 of Article 6 of the Law “On Consumer ...” dated December 21, 2013 No. 353-FZ, since it is intended only for consumer lending.
What about the minimum interest rate under the loan agreement? , there is no such limitation in the law. Moreover, paragraph 1 of Article 809 of the Civil Code of the Russian Federation suggests that a loan can be interest-free, that is, free for the borrower.
Change in percentage
According to paragraph 1 of Article 450 of the Civil Code of the Russian Federation, the parties to a loan transaction have the right at any time during the validity of the contract to change the amount of interest on it if they mutually agree. A unilateral change by the lender of interest is expressly prohibited by both Article 450 of the Civil Code of the Russian Federation and subparagraph 4 of paragraph 1 of Article 12 of the Federal Law No. 151 already mentioned by us (for clients of microfinance organizations).
When making changes, including reducing the amount of interest, the parties should remember that they will enter into force only from the moment of signing an agreement on this (paragraph 3 of Article 453 of the Civil Code of the Russian Federation). However, if desired, the parties in the text of the document may indicate a different procedure for the entry into force of the innovations they have adopted.
In this case, we can also talk about giving the agreement retroactive effect, that is, extending the effect of the changes to the period preceding their approval by the parties. Otherwise, in accordance with paragraph 4 of Article 453 of the Civil Code of the Russian Federation, all interest already paid at the previously concluded rate will remain valid. For example, the borrower is not entitled to demand the recalculation of previously made interest payments if the adopted changes will reduce the interest rate.
Untimely repayment of the loan and late payment of interest - consequences under Article 811 of the Civil Code of the Russian Federation
In practice, situations are not uncommon when the borrower does not pay off both the principal loan and the amount of interest accrued for its use in a timely manner. In case of untimely repayment of the debt, 2 options are possible, depending on whether the parties provide for special sanctions for delay in the agreement or not:
- If the procedure and amount of the penalty, in accordance with paragraph 4 of Article 395 of the Civil Code of the Russian Federation, are determined by agreement of the parties, the rules specified in the agreement apply.
- If the parties do not determine special sanctions for overdue debt, the provisions of Articles 395 and 811 of the Civil Code of the Russian Federation shall apply.
According to paragraph 1 of Article 811, in case of non-repayment of the loan, the borrower must pay the so-called default interest, accrued from the day when he had to fulfill the obligation until the moment of actual settlement.
It is important to remember that penalty interest is charged only on the principal amount of the loan, in accordance with paragraph 5 of Article 395 of the Civil Code of the Russian Federation. Exactly the same position is reflected in paragraph 15 of the Resolution of the Plenum of the Supreme Arbitration Court of the Russian Federation dated 08.10.1998 No. 14. At the same time, their accrual on the amount of interest payable is possible only if the parties directly indicate such a possibility in their agreement, realizing the consequences of this step. In the absence of an indication of the amount of penalty interest payable, the rules of paragraph 1 of Article 395 of the Civil Code of the Russian Federation are applied, according to which the penalty is charged based on the key rate of the Central Bank of the Russian Federation.
Interest income tax
When making loan transactions, the borrower does not need to pay VAT and income tax. These provisions are enshrined in paragraph 12 of Article 270 of the Tax Code of the Russian Federation. Similar rules apply to the lender when returning money or things borrowed to him. However, for the use of borrowed funds (things), a completely different procedure is applied with respect to interest - both penalty and ordinary.
Regarding VAT on interest received in relation to loan transactions, the rules of subparagraph 15 of paragraph 3 of Article 149 of the Tax Code of the Russian Federation are applied, according to which such operations are exempt from this tax. Income tax on the interest received will have to be paid, in accordance with paragraph 6 of Article 250 of the Tax Code of the Russian Federation. Interest earned in this case is treated as non-operating income.
As for the procedure for calculating tax, one should be guided by the provisions of paragraph 2 of Article 273 of the Tax Code of the Russian Federation (under the cash method of accounting), according to which the moment of receipt of income is the day when interest is received by the lender's cash desk. This rule It is used both for the simultaneous payment of the entire amount of interest, and for making payments in installments.
Summing up, we note that the procedure for paying interest by the borrower under a loan agreement is not an essential condition of the transaction, but is of great importance, since legal nature contracts of this kind presupposes its compensation. That is why the parties should be especially careful when agreeing on interest clauses during the conclusion of a loan agreement.
A. M. Khomich, senior expert of FBK Legal
One of the traditional forms of financing holding structures is intra-holding loans. However, lending to related parties involves certain tax risks arising from the application of transfer pricing rules. Consider these tax risks and possible ways to minimize them.
Let's take a hypothetical example. The loan transaction was concluded between two Russian related parties on the following terms:
the loan is provided in rubles;
cash provided to the borrower in parts;
interest for the use of borrowed funds is subject to accrual for each part of the loan amount provided to the borrower;
interest for the use of borrowed funds is accrued monthly during the entire period of use by the borrower of the loan amount on the actual balance of the debt for each part of the loan amount as of the beginning of each calendar day current month at the rate of 1/365 (1/366) of the annual interest rate (8.25%) for each day of using borrowed funds.
By virtue of paragraph 1 of Art. 2 and Art. 421 Civil Code The parties are free to establish their rights and obligations on the basis of the contract and to determine any terms of the contract that do not contradict the law.
Unless otherwise provided by law or the loan agreement, the lender, in accordance with paragraph 1 of Art. 809 of the Civil Code of the Russian Federation has the right to receive interest from the borrower on the loan amount in the amount and in the manner determined by the agreement.
From the totality of the above norms it follows that the parties to the loan agreement have the right to establish any amount of interest for the use of borrowed funds.
For the purposes of income taxation, income in the form of interest received under loan agreements is accounted for as non-operating income on the basis of clause 6 of Art. 250 tax code RF, expenses in the form of interest paid for the use of borrowed funds - as part of non-operating expenses on the basis of subpara. 2 p. 1 art. 265 of the Tax Code of the Russian Federation.
Features of accounting for interest on debt obligations are established by Art. 269 of the Tax Code of the Russian Federation. In accordance with paragraph 1 of the said article, debt obligations are understood as loans, commodity and commercial loans, loans, bank deposits, bank accounts or other borrowings, regardless of the method of their execution.
For debt obligations of any kind interest calculated on the basis of the actual rate is recognized as income (expense), unless otherwise provided by Art. 269 of the Tax Code of the Russian Federation.
For debt obligations of any kind arising as a result of transactions recognized in accordance with the Tax Code of the Russian Federation as controlled, income (expense) is interest calculated on the basis of the actual rate, taking into account the provisions of Section V1 of the Tax Code of the Russian Federation, unless otherwise provided by Art. 269 of the Tax Code of the Russian Federation.
Thus, the procedure for recognizing interest on debt obligations depends on whether the transactions resulting in such debt obligations are recognized as controlled for tax purposes or not.
Features of the recognition of interest on debt obligations arising from transactions that do not meet the criteria for recognizing them as controlled in accordance with the Tax Code of the Russian Federation, Art. 269 of the Code are not provided (with the exception of interest on those debt obligations, the debt on which, for the purposes of Chapter 25 of the Tax Code of the Russian Federation, is recognized as controlled).
Therefore, interest on debt obligations arising from transactions that are not recognized as controlled for taxation purposes are accounted for as part of non-operating income (expenses) in the amount calculated on the basis of the actual rate established by the relevant agreement.
Note that, establishing the taxpayer's right to recognize interest on the said debt obligations based on the actual rate, par. 2 p. 1 art. 269 of the Tax Code of the Russian Federation does not contain an indication of the need to apply the provisions of Section V1 of the Tax Code of the Russian Federation in this case. This means that when recognizing interest on debt obligations arising from transactions that are not recognized as controlled in accordance with the Tax Code of the Russian Federation, the actual rate is not subject to verification for its compliance with the market level.
Features of the recognition of interest on debt obligations arising from transactions recognized in accordance with the Tax Code of the Russian Federation as controlled transactions are established by clause 11 of Art. 269 of the Tax Code of the Russian Federation, depending on the grounds for recognizing such transactions as controlled.
recognize income
recognize expense interest calculated on the actual rate of such debt, if that rate:
Thus, since 2014, transactions between related parties, the place of registration of all parties to which is the Russian Federation, are recognized as controlled if the amount of income from such transactions for the corresponding calendar year exceeded 1 billion rubles.
According to paragraph 9 of Art. 10514 of the Tax Code of the Russian Federation the amount of income from transactions for a calendar year for the purposes of application said article is determined by adding the amounts of income received from such transactions with one person (related persons) for a calendar year, taking into account the procedure for recognizing income established by Chapter 25 of the Tax Code of the Russian Federation.
In addition, by virtue of the direct indication of paragraph 11 of Art. 10514 of the Tax Code of the Russian Federation, transactions are recognized as controlled, taking into account the provisions of paragraph 13 of Art. 1053, according to which the rules provided for by section V1 of the Code apply to transactions that entail the need for at least one party to such transactions to take into account income, expenses and (or) the value of extracted minerals, which leads to an increase and (or) decrease tax base for taxes provided for in paragraph 4 of Art. 1053 of the Tax Code of the Russian Federation.
Therefore, in order to recognize controlled transactions for the provision of loans should be guided by the provisions of sub. 10 p. 1 art. 251 and paragraph 12 of Art. 270, as well as paragraph 6 of Art. 250 and sub. 2 p. 1 art. 265 of the Tax Code of the Russian Federation, establishing the features of determining income and expenses under loan agreements.
Thus, a transaction concluded by a lender to provide a loan to a borrower who is related to him will be recognized as controlled for tax purposes if the amount of income from all transactions between these persons, including income in the form of interest under the loan agreement, exceeds 1 billion for the corresponding calendar year. rub. If the specified amount threshold is not exceeded, the analyzed loan transaction will not be recognized as controlled.
At the same time, it should be taken into account that when calculating the established sub. 1 p. 2 art. 10514 of the Tax Code of the Russian Federation, the amount threshold should be based on the market level of prices for transactions and, accordingly, take into account any income (profit, revenue) that could be received by one of the related parties from such transactions, but due to the indicated difference they were not received. With regard to transactions for the provision of loans, this means that in the event that the interest rate established by the loan agreement deviates from the market level, the amount of income from such transactions for the purpose of recognizing them as controlled should be determined based on the market, and not on the actual level of the interest rate.
The legitimacy of this conclusion is confirmed by the official position of the Ministry of Finance of Russia on the issue of determining the amount of income for a calendar year for the purpose of recognizing controlled transactions for the provision of an interest-free loan between related parties, according to which any income (profit, revenue) that could be received by one of the related parties on such transactions, but due to the said differences were not received by him, should be taken into account for tax purposes with this person. At the same time, the financial department notes that when determining the amount of income from transactions federal agency executive authority, authorized to control and supervise taxes and fees, has the right to verify the compliance of the amounts of income received from transactions with the market level, taking into account the provisions of Chapters 142 and 143 of the Tax Code of the Russian Federation (see, for example, Letters of the Ministry of Finance of Russia dated October 2, 2013 No. 03 -01-18/40821, October 5, 2012 No. 03-01-18/7-137, July 18, 2012 No. 03-01-18/5-97 and November 25, 2011 No. 03- 01-07/5-12).
As noted earlier, the procedure for recognizing income in the form of interest on loans for tax purposes depends on whether the transaction for the provision of the corresponding loan is recognized as controlled or not.
, That lender will be entitled to recognize as part of non-operating income the amount of interest calculated on the basis of the actual rate under the loan agreement, provided that this rate exceeds 0% of the key rate of the Central Bank of the Russian Federation for the period from January 1 to December 31, 2015 and 75% of the key rate of the Central Bank RF - starting from January 1, 2016
According to the conditions of the example under consideration, the interest rate established by the loan agreement is fixed and is 8.25%. Therefore, for the purposes of calculating the minimum value of the interval limit values interest rates on debt obligations, above which income in the form of interest on a loan will be recognized by the lender based on the actual rate, the key rate of the Central Bank of the Russian Federation should be understood as the corresponding rate in effect on the date of attraction of funds.
Under the terms of the loan agreement under consideration, the funds are provided to the borrower in installments. With this procedure for providing borrowed funds, the interest rate established by the loan agreement will need to be checked for exceeding the minimum value of the interval of maximum interest rates on debt obligations as of the date of provision of each part of the loan amount to the borrower.
At the same time, in order to correctly calculate the amounts of recognized income in the form of interest on a loan, the lender will need to ensure that the accrued interest is kept in the context of each part of the loan amount provided to the borrower. In the analyzed situation, under the terms of the concluded loan agreement, interest is accrued on the actual balance of the debt for each part of the loan amount, which allows the lender to ensure that the accrued interest is kept in the specified way.
During the lender has the right to recognize income in the form of interest on the loan based on the actual rate under the loan agreement at any value of the key rate of the Central Bank of the Russian Federation, since for the specified period the minimum value of the range of maximum interest rates on debt obligations is set at 0%.
Beginning from January 1, 2016. the lender will be entitled to recognize income in the form of interest based on the actual rate under the loan agreement only if the interest rate established by the loan agreement - 8.25% - exceeds 75% of the key rate of the Central Bank of the Russian Federation in force on the date of provision of the relevant part of the loan to the borrower. This condition will be met if the key rate of the Central Bank of the Russian Federation does not exceed 11%.
When the key rate of the Central Bank of the Russian Federation is set at a level above 11% and, accordingly, stipulated by the treaty loan interest rate - 8.25% - will be less than 75% of the key rate of the Central Bank of the Russian Federation, effective on the date of provision of the relevant part of the loan amount to the borrower, then the interest calculated on the basis of the actual rate, taking into account the provisions of Section V1 of the Tax Code of the Russian Federation, will be recognized as the lender's income. In other words, for the purposes of recognizing income in the form of interest on a loan, the lender will need to determine whether the interest rate established by the loan agreement corresponds to the market level, applying the provisions of Art. 1057 of the Tax Code of the Russian Federation methods.
If the interest rate established by the loan agreement corresponds to the market level, the lender will be entitled to recognize income in the form of interest accrued under the loan agreement, based on the actual rate.
If the interest rate under the loan agreement is below the market level, then the income in the form of interest on the loan will be subject to determination based on the market level of interest. The need to determine in this case the amount of income to be recognized based on the market level of interest follows from paragraph 1 of Art. 1053 of the Tax Code of the Russian Federation, according to which, if transactions between related parties create or establish commercial or financial conditions, other than those that would take place in transactions recognized in accordance with Section V1 of the Tax Code of the Russian Federation as comparable, between persons who are not interdependent, then any income (profit, revenue) that could be received by one of these persons, but due to the specified difference was not received by him, are taken into account for the purposes of taxation from this person.
It should be borne in mind that on the basis of paragraph 9 of Art. 10514 of the Tax Code of the Russian Federation, when determining the amount of income from transactions between related parties, the federal executive body authorized for control and supervision in the field of taxes and fees, for the purposes of this article, has the right to verify the compliance of the amounts of income received from transactions with the market level, taking into account the provisions of Chapters 142 and 143 of the Tax Code RF. If, as a result of this audit, the tax authority establishes that the amount of income recorded by the lender in the form of interest on the loan is calculated on the basis of an interest rate that is below the market level, then the lender will have a high risk of additional tax payable to the budget, as well as charging the corresponding amounts penalties and fines.
If the transaction to provide a loan , then the lender will be entitled to recognize as part of non-operating income the amount of interest calculated on the basis of the actual rate under the loan agreement, regardless of the ratio of the latter to the key rate of the Central Bank of the Russian Federation, and also regardless of its compliance (non-compliance) with the market level.
The procedure for recognizing expenses in the form of interest under a loan agreement arising from borrower, also depends on whether the transaction for obtaining a loan is recognized as controlled for tax purposes or not.
will be considered controlled, then the procedure for the borrower to recognize the expense in the form of interest calculated under the loan agreement will be as follows.
During from January 1 to December 31, 2015 the borrower will be entitled to recognize as non-operating expenses the amount of interest calculated on the basis of the actual rate under the loan agreement, provided that this rate is less than 180% of the key rate of the Central Bank of the Russian Federation in force on the date of granting the corresponding part of the loan.
Since August 3, 2015, the key rate of the Central Bank of the Russian Federation has been set at 11%. Thus, 180% of the current key rate of the Central Bank of the Russian Federation is 19.8%, which is more than the interest rate under the analyzed loan agreement - 8.25%.
Therefore, when receiving a part of the loan amount during the period of the key rate of the Central Bank of the Russian Federation at the level of 11%, the borrower is entitled to recognize as part of non-operating expenses the interest calculated on such part of the loan, in full based on the actual rate under the agreement.
At the same time, we note that in connection with the provision of a loan in parts, the borrower, as well as the lender, must ensure that the calculated interest is kept in the context of the provided parts of the loan. Such an interest accounting procedure will allow the borrower to correctly determine the amount of expenses in the form of interest recognized for income tax purposes.
If before December 31, 2015 inclusive the key rate of the Central Bank of the Russian Federation is lowered to 4.5% (or lower) and, accordingly, the interest rate established by the agreement - 8.25% - exceeds the statutory maximum value of the range of limit values for interest rates on debt obligations , then the borrower's expense in the form of interest calculated on that part of the loan that will be provided to him during the period of the key rate of the Central Bank of the Russian Federation in the amount of 4.5% (or lower) will be recognized as interest calculated on the basis of the actual rate, taking into account the provisions of section V1 NK RF.
However, the reduction of the key rate of the Central Bank of the Russian Federation in current year up to 4.5%, according to the author, is extremely unlikely. In this regard, the probability that the interest rate established by the loan agreement under consideration will exceed in 2015 the maximum value of the range of limit values of interest rates on debt obligations and, accordingly, the borrower will need to determine the expense in the form of interest under the loan agreement, taking into account the provisions of section V1 of the Tax Code of the Russian Federation, is also estimated by the author as extremely low.
If the key rate of the Central Bank of the Russian Federation is nevertheless lowered to 4.5%, then the borrower's expenses in the form of interest on the loan will be recognized for tax purposes in the following way.
If the interest rate established by the loan agreement corresponds to the market level, the borrower will be entitled to recognize the expense in the form of interest calculated under the loan agreement, based on the actual rate.
If the interest rate under the loan agreement is higher than the market level, then for the purposes of calculating income tax, the expense in the form of interest on the loan will be subject to determination based on the market level of interest.
If, as a result of checking the completeness of the calculation and payment of taxes in connection with transactions between related parties, the tax authority reveals that the amount of expenses recorded by the borrower in the form of interest on the loan was calculated by him based on an interest rate that is higher than the market level, then the borrower will have a high risk of refusal to recognize that part of the expenses that will be accounted for by such an excess, and, as a result, an additional charge of tax payable to the budget, accrual of the corresponding amounts of penalties and fines.
Beginning from January 1, 2016 the borrower will be entitled to recognize the expense in the form of interest under the loan agreement based on the actual rate, if the rate established by the agreement - 8.25% - is less than 125% of the key rate of the Central Bank of the Russian Federation in force on the date of provision of the corresponding part of the loan.
This condition will be violated only if the key rate of the Central Bank of the Russian Federation is set at 6.5% or lower. In this case, the procedure for calculating the amount of expenses that the borrower will be entitled to recognize for tax purposes will be similar to the procedure for calculating the amount of recognized expenses in case of non-compliance with the conditions of clause 11 of Art. 269 of the Tax Code of the Russian Federation, set forth earlier in relation to the period from January 1 to December 31, 2015.
If a loan transaction will not be considered controlled, then the borrower will be entitled to recognize as non-operating expenses the amount of interest calculated on the basis of the actual rate under the loan agreement, regardless of the ratio of the latter to the key rate of the Central Bank of the Russian Federation, and also regardless of its compliance (non-compliance) with the market level.
Thus, if the analyzed conditional loan transaction is not recognized as controlled for tax purposes, then neither the lender nor the borrower, in the opinion of the author, will have any tax risks in terms of the legitimacy of recognizing income (expenses) in the form of interest on loan based on the actual rate, since in this case there will be no grounds for applying the provisions of Section V1 of the Tax Code of the Russian Federation.
If the analyzed loan transaction is recognized as controlled for tax purposes, then tax risks may arise for the lender and (or) borrower only if the interest rate established by the loan agreement exceeds the minimum and (or) maximum values established by subpara. 1 p. 12 Art. 269 of the Tax Code of the Russian Federation of the range of limit values of interest rates on debt obligations, and at the same time it will not correspond to the market level. In this case, the tax authority will have the right to determine the tax consequences of the analyzed loan transaction based on the market level of interest rates for similar loans.
These risks can be avoided if the loan agreement establishes such an interest rate, the value of which will be within the range of limit values of interest rates on debt obligations in force during the period of the loan.
However, this method can guarantee the absence of tax risks in terms of the legitimacy of recognizing income (expenses) in the form of interest on a loan based on the actual rate, only if the relevant loan agreement provides for a one-time provision of the entire loan amount, since only with this procedure for providing funds, the condition for finding the interest rate established by the loan agreement within the range of limit values of interest rates will be met throughout the term of the loan agreement.
When a loan is provided in parts, the values of the minimum and maximum limits of the range of limit values of interest rates on debt obligations will be subject to determination on the date of provision of each part of the loan, and, accordingly, in case of a significant change in the key rate of the Central Bank of the Russian Federation towards a decrease or increase and the interest rate under the loan agreement remains unchanged the condition that the interest rate established by the agreement is within the range of limit values of interest rates on debt obligations may be violated.
If a one-time provision of the entire loan amount is not possible, for example, due to economic reasons, the parties are entitled to conclude separate loan agreements for each amount of money actually provided on loan, setting an interest rate taking into account the current level of the key rate of the Central Bank of the Russian Federation.
Setting an interest rate by indicating a certain percentage of the key rate of the Central Bank of the Russian Federation, effective on the date of provision to the borrower of the relevant part of the loan, is permissible from the point of view of civil law. However, with this method of setting, the interest rate cannot be considered fixed, since in fact its value depends on the value of the key rate of the Central Bank of the Russian Federation as of each specific date.
Therefore, when setting an interest rate in the form of a certain percentage of the key rate of the Central Bank of the Russian Federation in order to calculate the range of limit values for interest rates on debt obligations, the key rate of the Central Bank of the Russian Federation should be understood as the corresponding rate in effect on the date of recognition of income (expenses) in the form of interest in accordance with Chapter 25 of the Tax Code of the Russian Federation, and not on the date of provision of borrowed funds (subclause 2, clause 13, article 269 of the Tax Code of the Russian Federation). In practice, the provision of borrowed funds and the recognition of income (expenses) in the form of interest on a loan, as a rule, diverge in time: the provision of borrowed funds precedes the recognition of income (expenses) in the form of accrued interest on a loan. In this regard, setting the interest rate on the loan at the level of 75% of the key rate of the Central Bank of the Russian Federation, effective on the date of granting the corresponding part of the loan, does not guarantee that, as of the date of recognition of expenses (income) in the form of interest on the loan, the condition for finding the interest rate established by the loan agreement within the range of limit values of interest rates on debt obligations, which, with this method of setting the rate, will be calculated based on the key rate of the Central Bank of the Russian Federation on the date of recognition of income (expenses) in the form of interest on the loan, will not be violated.
Guarantee compliance with the condition that the interest rate established by the loan agreement is within the range of limit values of interest rates and thereby eliminate the risk of determining tax authorities tax consequences making the analyzed transaction to provide a loan based on the market level of interest on similar loans will allow fixing the interest rate on the loan by indicating a certain percentage of the key rate of the Central Bank of the Russian Federation, which is in effect not on the date of granting the corresponding part of the loan to the borrower, but as of the date of recognition of income (expenses) in the form of interest in accordance with Chapter 25 of the Tax Code of the Russian Federation. At the same time, the value of the percentage of the key rate of the Central Bank of the Russian Federation established by the loan agreement as of the date of recognition of income (expenses) in the form of interest for tax purposes should be within the corresponding values established by subpara. 1 p. 12 Art. 269 of the Tax Code of the Russian Federation.
With this method of setting the interest rate, the limit values of the interest rate interval for debt obligations are to be determined based on the value of the key rate of the Central Bank of the Russian Federation in force on the date of recognition of income (expenses) for tax purposes.
Thus, when setting the interest rate on a loan by pointing to a certain percentage of the key rate of the Central Bank of the Russian Federation, effective on the date of recognition of income (expenses) in the form of interest, the value of such a rate will always be within the range of limit values of interest rates on debt obligations and, accordingly , there will be no grounds for revising the amount of income (expenses) recognized for tax purposes in the form of interest as a result of the application of transfer pricing rules (provided that the value of the interest rate of the key rate of the Central Bank of the Russian Federation established by the loan agreement is within the range of maximum interest rates on debt obligations, established by subparagraph 1, paragraph 12, article 269 of the Tax Code of the Russian Federation).
The author does not see any other ways to minimize tax risks arising from the right of tax authorities to determine the tax consequences of transactions between related parties based on the market level of prices for the relevant goods (works, services).
If an additional agreement is concluded to a previously valid loan agreement with a fixed interest rate, on the basis of which the interest rate for newly issued and (or) previously issued loan amounts changes from a certain date, then the parties to the agreement may face the following tax risks.
When a loan is provided in installments, each new tranche in which funds are transferred to the borrower should be considered as new debt obligation , since by virtue of paragraph 1 of Art. 807 of the Civil Code of the Russian Federation, a loan agreement is considered concluded from the moment the money or other things are transferred. Similar position on this issue the Ministry of Finance of Russia also adheres (see, for example, letter dated April 15, 2013 No. 03-03-06/1/12502).
In this regard, in the event of the conclusion of an additional agreement to the loan agreement, on the basis of which the interest rate on newly issued and (or) previously issued loan amounts is changed, the tax consequences in terms of determining the amount of income (expenses) recognized for tax purposes in the form of interest, by in our opinion, should be considered for those parts of the loan that were provided before the change in the interest rate, and for those parts of the loan that will be provided after the change, separately.
Tax consequences for loan amounts that were granted before the conclusion of an additional agreement on changing the interest rate
The limit values of the interest rate interval are determined on the basis of the key rate of the Central Bank of the Russian Federation (subclause 1, clause 12, article 269 of the Tax Code of the Russian Federation).
The criterion for applying one or another procedure for determining the key rate of the Central Bank of the Russian Federation for the purposes of calculating the range of limiting values of interest rates on debt obligations is the interest rate on the corresponding debt obligation.
Tax consequences for loan amounts that were granted after the conclusion of an additional agreement on changing the interest rate
For debt obligations that arose after the conclusion of an additional agreement on changing the interest rate on the loan, the new interest rate will apply. The change in interest rate will not fall within the term of such debt obligation.
Therefore, for debt obligations that arose after a change in the interest rate on a loan, the interest rate will be unchanged and, accordingly, in relation to such debt obligations, the key rate of the Central Bank of the Russian Federation should be understood as the corresponding rate that was in force on the date of attraction of funds. So the order tax accounting income (expenses) on such obligations and possible tax risks will be similar to the procedure and risks set forth earlier in relation to debt obligations, the interest rate on which is fixed and does not change during the entire period of their validity.
In conclusion, we note once again: intercompany lending does not in itself entail any tax risks. However, under certain actual circumstances a lender and a borrower that are related parties may face tax risks due to the application of transfer pricing rules.
These risks may arise if:
the transaction under consideration to provide a loan will be recognized as controlled for tax purposes And
the interest rate established by the loan agreement will go beyond the limits of the minimum and (or) maximum values established by subpara. 1 p. 12 Art. 269 of the Tax Code of the Russian Federation of the range of limit values of interest rates on debt obligations, and at the same time it will not correspond to the market level.
In this case, the tax authority will have the right to determine the tax consequences of the loan transaction based on the market level of interest rates for similar loans.
These risks can be avoided if the loan agreement establishes such an interest rate, the value of which will be within the range of limit values of interest rates on debt obligations in force during the period of the loan. In this case, the loan amount must be provided at a time in full, or a separate agreement must be concluded for each of the loan amounts provided.
Setting an interest rate by specifying a certain percentage of the key rate of the Central Bank of the Russian Federation (in particular, 75%), effective on the date of provision of the corresponding part of the loan, does not exclude the occurrence of grounds for applying the provisions of Section V1 of the Tax Code of the Russian Federation to the transaction in question and, as a result, the indicated risks in connection with their use. This is due to the fact that at this method setting the interest rate on a loan, the minimum and maximum values of the range of limit values of interest rates on debt obligations will depend on the value of the key rate of the Central Bank of the Russian Federation on the date of recognition of income (expenses) in the form of interest and, accordingly, cannot be determined in advance.
The risk of determination by the tax authorities of the tax consequences of the analyzed transaction to provide a loan based on the market level of interest on similar loans will be eliminated by setting an interest rate by indicating a certain percentage of the key rate of the Central Bank of the Russian Federation in force on the date of recognition of income (expenses) in the form of interest for tax purposes. At the same time, the value of the specified percentage of the key rate of the Central Bank of the Russian Federation must be within the corresponding limit values established by sub. 1 p. 12 Art. 269 of the Tax Code of the Russian Federation.
As for tax risks, if the parties conclude an additional agreement on changing the interest rate on loans, then the extension of such an agreement to previously issued loan amounts is associated with tax risks, since the procedure for calculating income (expenses) in the form of interest in such a situation is not established by the Tax Code of the Russian Federation and , respectively, the legitimacy of the application of any of possible ways calculation of the amount of income (expenses) recognized for tax purposes in the form of interest can be challenged by the tax authorities.
For debt obligations that arose after a change in the interest rate on a loan, new rate will be permanent (provided that during the term of such debt obligations the parties do not enter into new additional agreements on changes in the interest rate on the loan, the effect of which will be extended to previously issued loan amounts). Accordingly, the procedure for tax accounting of income (expenses) on such obligations and possible tax risks will be similar to the procedure and risks set forth earlier for debt obligations, the interest rate for which is fixed and does not change during the entire period of their validity.
The specified norm establishes the features of recognizing controlled transactions between related parties, the place of registration, or the place of residence, or the place of tax residence of all parties and beneficiaries in which the Russian Federation is.
Since, according to the conditions of the this article For example, the place of registration of both the lender and the borrower is the Russian Federation, transactions between them can be recognized as controlled on the basis of paragraph 2 of Art. 10514 of the Tax Code of the Russian Federation. In this regard, the established par. 3 sub. 1 p. 12 Art. 269 of the Tax Code of the Russian Federation minimum and maximum values intervals of limit values of interest rates on debt obligations arising from transactions recognized as controlled on grounds other than the grounds specified in paragraph 2 of Art. 10514 of the Tax Code of the Russian Federation, are not given in this article.
With regard to the size of the sum criterion for the purposes of recognizing transactions between related parties as controlled by the Tax Code of the Russian Federation, exceptions are established depending on the circumstances in connection with the presence of which transactions are recognized as controlled. For transactions recognized as controlled on the basis of sub. 2, 4–7 p. 2 art. 10514 of the Tax Code of the Russian Federation, the sum criterion is set at the level of 60 million rubles, for transactions recognized as controlled on the basis of sub. 3 p. 2 art. 10514 of the Tax Code of the Russian Federation, - at the level of 100 million rubles. The provisions of sub. 2–7 p. 2 art. 10514 of the Tax Code of the Russian Federation are subject to application depending on the subject composition of transactions between related parties and their subject matter.
Please note: for the purposes of calculating the established sub. 1 p. 2 art. 10514 of the Tax Code of the Russian Federation of the amount threshold, the concept of "income" is used in relation to both parties to the transaction. Thus, when calculating the amount of income from transactions between related parties for the purpose of recognizing them as controlled, one should take into account both those transactions in which one of the parties received income and those transactions in which such party received an expense, since for the other party to the transaction (counterparty ) the last transactions will be "profitable".
Similar conclusions are contained in the letters of the Ministry of Finance of Russia dated May 23, 2012 No. 03-01-18 / 4-67 and dated April 23, 2012 No. 03-03-18 / 3-56.
Provided that during the period of validity of such debt obligations, the parties do not enter into new agreements on changing interest rates on previously issued loan amounts.
Interest-bearing loan agreements between legal entities are a fairly common phenomenon. Many firms choose this method of raising funds, since contacting banking organizations often turns out to be less profitable.
This is due to the fact that partner companies willingly provide loans to each other on attractive terms. You can learn about the features of this type of agreement from this article.
Peculiarities
One of the most common agreements in legal practice is an interest-bearing loan agreement. It can be concluded among themselves by everyone - both citizens and legal entities.
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The parties to the agreement transfer funds to each other for a predetermined period and pay the debt along with accrued interest.
In general, a loan agreement is considered interest-bearing by default, even if this condition is not spelled out in the document itself.
If the document does not say anything about the procedure for calculating and paying interest, the fee for using borrowed funds will be calculated based on the current refinancing rate.
If there is no procedure for paying interest in the document, their payments will be made monthly from the date of repayment of the full loan amount.
Moreover, if the lender, together with the transfer of the loan, performs transactions subject to VAT, then, in accordance with paragraph 4 of Article 149 of the Tax Code of the Russian Federation, it needs to keep separate records.
For this purpose, to calculate the ratio indicated in paragraph 4, it is necessary to take only interest, and the size of the loan itself should not be taken into account.
The following point is also important: the lender cannot claim a refund of input VAT on goods, works or services that it uses in activities related to the provision of a loan.
This amount will be included in the cost of work performed or services provided. This idea is expressed in .
However, if the amount of non-taxable transactions does not exceed 5% of the line defined by paragraph 4 of Article 170 of the Tax Code of the Russian Federation, then the lender may not keep separate records and is entitled to a VAT refund in full size ().
If the loan is granted in monetary form, the amount of accrued interest must be attributed to the taxable base for calculating VAT (clause 2 clause 1).
This obligation arises at the time of the direct transfer of interest. The calculation of the tax itself is carried out at the estimated rate (clause 4).
The lender is obliged to generate an invoice for interest and record it in the sales book (used in calculating VAT, paragraph 18).
income tax
If the lender company receives a fee in the form of interest for providing a loan, this amount will be included in non-operating income, which means that it will need to pay income tax (the interest rate existing in the company's region is applied).
The lender must attribute the interest received under the agreement to non-operating income, regardless of the form in which the loan is provided (monetary or non-monetary) - paragraph 6.
With the cash method, interest is taken into account at the time of their direct transfer ().
If the lender uses the accrual method, interest will be included in non-operating expenses at the end of the reporting period (provided that the term of the agreement falls on two or more reporting periods).
This is stated in paragraph 6 and paragraph 4 of the Tax Code.
tax accounting
According to employees tax service, interest under a loan agreement (if its validity spans two or more reporting periods) is recognized in income evenly at the end of the month of the corresponding reporting period, and this does not depend on the terms and actual payment specified in the agreement.
At the same time, some courts consider that only interest for the period of their actual transfer should be included in income.
Separately, it is necessary to consider the specifics of tax accounting for interest on loans denominated in foreign currency:
- the loan is provided in foreign currency, and interest is paid in rubles. If the lender uses the accrual method, then a change in the exchange rate may cause a positive or negative difference between accrued and received interest. With an increase in the exchange rate, a positive difference is formed, with a decrease, respectively, a negative one. Applicable here general order accounting: a positive difference goes to non-operating income (Article 250 of the Tax Code of the Russian Federation), negative - to non-operating expenses ();
If the lender uses the cash method, there will be no difference, since interest will be recorded as income after its direct transfer (Article 273 of the Tax Code of the Russian Federation).
- the loan is provided in foreign currency, interest is also paid in foreign currency. The amount of the benefit received in foreign currency is converted into rubles (). The recalculation is carried out at the current exchange rate of the Central Bank or on the last day of the reporting period.
If, as a result of a change in the rate, positive or negative differences arise, they will be taken into account as non-operating income or expenses of the lender.
If the cash method is applied, no difference can arise, since the recalculation is carried out on the date of direct payment of interest.
Sample contract
To draw up an interest-bearing loan agreement between legal entities, a standard loan agreement form is used.
This means that the document will list all the same provisions:
- the subject of the agreement (the amount of the loan, the amount of interest and the terms of payment are indicated here);
- rights and obligations of the parties;
- the duration of the contract;
- additional conditions, etc.
Among other things, annexes can be drawn up to an interest-bearing loan agreement between organizations:
- loan disbursement schedule;
- loan repayment schedule;
- interest payment schedule.
From additional documents usually are:
- additional agreement;
- protocol of disagreements;
- dispute resolution protocol.
How to avoid mistakes when drawing up an interest-bearing loan agreement between legal entities
Any errors and inaccuracies in the interest-bearing loan agreement can lead to the most undesirable consequences, up to and including its invalidation. To avoid this, it is necessary to carefully monitor all the information entered.
Check how correctly the loan amount, repayment terms, interest rate for the use of funds are indicated in the agreement (if the rate is not indicated, interest will be charged at the rate of the Central Bank of the Russian Federation), the amount of penalties, etc.
Carefully review how complete and accurate specified details sides.
By mutual agreement of the borrower and the lender, any changes can be made to the agreement.
If the parties to the agreement decide to change any material terms, a written supplementary agreement must be drawn up to the main contract.
An interest-bearing loan agreement between organizations is concluded quite often, just as often mistakes are made when drawing up a document.
To avoid this, it is necessary to carefully check all clauses of the agreement.
If the qualifications of the company's employees are not high enough, it is advisable to use the services of professionals - this will help to avoid mistakes and, as a result, complex and irreparable consequences.
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