Determining marketing costs is a rather difficult task, because:

marketing costs ensure the process of selling goods;
marketing costs are of an investment nature and can bring income in the short term;
· financial planning marketing costs are carried out when developing appropriate budgets (research, communication policy, etc.).

When determining marketing costs, methods are widely used:

Top-down - first, the total cost is calculated, and then this amount is distributed to individual marketing activities. In this case, the approaches shown in Fig. 7.1;
· "bottom-up" - first, the costs of individual marketing activities are calculated, and then these values are summed up according to the cost calculation method using the relevant norms and standards (calculations are carried out by the enterprise's marketing service or external experts on a contractual basis).

Rice.

The costs of individual marketing activities are divided into fixed and variable.

Fixed costs of marketing - the costs necessary to constantly maintain the operation marketing system at the enterprise. They include costs for:

maintenance of marketing staff (salary, travel expenses etc.);
systematic marketing research;
Creation of a bank of marketing information for enterprise management;
· Financing of works aimed at improving the product range of the enterprise.

Variable costs for marketing costs associated with changes in the market situation and market conditions, the adoption of new strategic and tactical decisions.

The marketing department prepares cost estimates in the following areas:

marketing research costs;
the cost of developing new products;
distribution costs;
promotion costs.

A modern method of planning marketing costs is the method of marginal marketing budgets, based on the fact that the elasticity of consumer response varies with the intensity of marketing efforts. At the same time, such spending on the use of each element of the marketing mix is determined, which leads to the best results (the largest effect size).

1. The salary of employees of the marketing service will be equal to 15,000 rubles.
2. The number of bets will be equal to 1.
3. Employee bonus is 20% of salary.
4. 30% of the district coefficient, 20% of the northern coefficient will be accrued on the salary.

That is, labor costs will be: 1 * 15,000 + 3,000 + 9,000 = 27,000 rubles.

5. 30.2% will be deducted from the wages of employees for social insurance.

Insurance premiums:

27000 * 30.2% \u003d 8154 rubles.

The cost of maintenance and operation of equipment will be:

35154*50%=17577 rub.

Thus, the monthly cost of maintaining the marketing service is

27000+8154+17577=52731 rub. or 52,731 thousand rubles.

In addition to the costs of maintaining the marketing service, marketing research costs are allocated, which amount to 0.3% of income. Thus, 0.3% of the income goes to the collection and analysis of data that is required for marketing activities.

Using the presented minimum marketing costs at the Lot-Mebel LLC enterprise, which is 48850.42 thousand rubles, the enterprise will be able to conduct market research, identify customer preferences, improve product sales and enter the world market.

Marketing costs in each month can be different, there is no need to conduct an in-depth market analysis every month, since with a full and in-depth analysis at the first stage of the study, it is possible to express a stable pattern of development in the industry, in the preference of buyers. The effectiveness of a deep market analysis is once every six months or a year.

In addition to allocating the costs of conducting market research, it is necessary to review the costs of maintaining the marketing service annually. The percentage of bonuses may vary depending on the stability of the economic condition of the enterprise and on the efficiency of the department's employees.

In previous articles of our magazine devoted to marketing function, we touched on a number of organizational issues: the structure of the marketing service, job descriptions for employees of marketing departments, etc. The next topic in turn is the definition of marketing costs. We have delivered this topic to the number based on the following arguments. Most firms are now experiencing resource constraints. There are, of course, exceptions, but the dominance of austerity financial resources exists. In this situation, it becomes quite possible to move marketing costs to "later", partly due to a lack of understanding of the importance of this management function, partly due to a lack of knowledge in the field of resource maneuvering within the marketing function. In this regard, when preparing an article for the issue, we asked our clients to send us their marketing budgets, broken down by article. The results of our generalizations, as well as additions from the statistics of the American Bank Marketing Association, the American Association of Clothing Manufacturers, the American Association of Retailers are in front of you. Perhaps some cost items will seem irrelevant to you in your conditions. It's OK. Just put "0" against these lines for now, but be sure that sooner or later they will be useful to you.

So, marketing is aimed at creating and maintaining a positive image of the organization, maximizing the use of its resources to identify, promote and meet market needs for products and services on a profitable basis. In this context, from the standpoint of determining cost items, 4 blocks can be distinguished within the marketing function:

A. Advertising.

a) motivating the client to purchase or use a product-service that provides benefits, guarantees or satisfaction to the user,

b) transfer of information aimed at strengthening the reputation or position of the advertiser.

B. Marketing research. The use of various methods and tools on an ongoing and systematic basis to analyze information related to:

Analysis of this market:

Who is an existing and potential client.

Geography of customer placement.

What products and/or services the client wants and what he really needs.

Where the client prefers to receive services, or how and when they should be provided.

What are the conditions for competition.

Meeting the needs of existing or potential clients or their wishes.
Evaluations of existing or potential customers in terms of products or services provided, personnel, policies and procedures, etc.

B. Public relations. A permanent and ongoing program of action designed to involve the firm in the social, cultural, educational, environmental, and economic life of a region or larger administrative entity (eg, country).

D. sales promotion. A set of actions to enhance the effectiveness of advertising and customer contact programs by increasing awareness and knowledge about products or services at the point of sale.

We present these well-known truths for the sole purpose of linking upcoming cost lists to the above marketing blocks. Now let's move on to the cost items.

7. Purchase of seats at trade shows, fairs, etc.

15. Costs of photographs and payment of models participating in advertising.

17. Posters, displays, etc. placed inside the firm for promotional purposes.

MARKETING RESEARCH COSTS

1. Research on advertising pre-testing and advertising effectiveness.

2. Payment of marketing research consultants.

3. Research related to the introduction of new products and services.

4. Research related to the image of the company; public opinion research.

5. Quarterly, semi-annual and annual selective market researches regarding the degree of penetration and perception.

6. Testing and evaluation of sales promotion activities.

Ultimately, all costs are spent on researching the potential of new products and services, market share, selection of branches and affiliates, company image, advertising effectiveness, and preliminary testing of proposed public relations projects.

PUBLIC RELATIONS COSTS

2. Celebration of anniversaries and significant dates.

4. Awards given in charitable events.

5. Calendars.

6. Greeting cards.

7. Financing of activities carried out by municipal authorities.

8. Donations and grants.

9. Production of displays for the needs of municipal authorities.

10. Paying public relations consultants.

11. Payment for special events offered to the public.

12. Gifts and souvenirs with the logo of the organization.

14. Thanksgiving letters clients for agreeing to do business with the company, various types of congratulations and their mailing list.

15. Production geographical maps with the logo of the company and its location.

16. The cost of spending the day" open doors"firms.

17. Sponsoring creative and sports teams and cultural/sporting events.

18. Press conferences.

19. Scholarship costs.

20. Costs for weather and time systems for installation in public places without a company logo.

21. Costs of speech writers outsourced.

23. Development of a trademark or company logo.

SALES PROMOTION COSTS (a separate group of costs aimed at expanding knowledge about the company's products and services both outside and inside it).

1. Audiovisual materials, including slides, audio and video cassettes for demonstration during presentations related to the implementation of products and services.

2. Manufacture of items (banners, boxes, etc.) for use at points of sale for products and services.

3. Souvenirs for clients starting business with the firm.

4. Prizes or bonuses for employees who attract new clients.

5. Letters related to the increase in sales volumes and their mailing list.

6. Training of personnel related to the sale of products and services.

7. Organization of meetings with new clients

Determination of marketing costs is a rather difficult task. This complexity is due to understanding the essence of marketing costs and how to determine them.

The essence of marketing costs is expressed as follows:

Marketing costs are not overhead costs, but are costs, ensuring the sale of goods;

marketing costs are those costs that investment character, which in the future can bring considerable income;

financial planning of marketing costs is carried out in the form of developing a system of interrelated budgets.

4.6.1. Methods for determining the total cost

To determine the total cost of implementing marketing activities one of the methods can be used: "top - down" or "bottom - up".

Top-down method involves first calculating the total amount of costs, and then distributing it to individual marketing activities. With this approach, the following approaches can be used:

1. Definition marginal profit or sales response functions (a given level of sales and profits at a certain level of marketing costs).

2. Calculation of the percentage of sales (linear dependence).

3. Calculation of the percentage of profit (linear dependence).

4. Determination of costs for the target profit (share of profit).

5. Assessment of competitive parity (“costs like a competitor”).

bottom-up method involves first calculating the costs of individual marketing activities, and then summing up all the costs to determine their total value. With this approach, the method of costing for individual activities is used on the basis of accepted norms and standards of expenditure or on a contractual basis (in the case of involving external organizations).

4.6.2. Methods for determining the costs of individual marketing activities

Marketing costs can be conditionally divided into fixed and variable.

Permanent part marketing costs - these are the costs that are necessary to constantly maintain the functioning of the marketing system in the enterprise. This usually includes costs for:

Regular marketing research and creation of a marketing data bank for enterprise management;

Financing of work on continuous improvement of the company's commercial products.

Maintaining the existence of a marketing system in an enterprise is cheaper than creating it every time anew (depending on the prevailing favorable or unfavorable situations). Such costs are justified, since they contribute to the constant obtaining of information about market conditions, the actions of competitors, the development of demand, and also allow you to monitor the level of competitiveness of the company's products in the market, etc.

Variable part of marketing costs represents the costs of marketing caused by changes in the market situation and the adoption of new strategic and operational decisions.

Most often, both the fixed and the variable parts of the costs are formed during the development of promising and current plans marketing activities. The basis is budgets, determining the amount of resources, and estimates, forming directions of expenses.

Marketing research costs include costs associated with attracting various sources of information, subscribing to information systems, attracting specialized organizations to develop programs and conduct “field” research, pay consultants, etc.

The costs of developing new products cover research and development and development work, the acquisition of know-how, the purchase of new production materials and equipment, the involvement of consultants and experts, etc.

Distribution costs include costs for the formation of dealer-distributor networks, the organization of branded trade, after-sales service sales force training, etc.

Promotion costs are quite diverse costs:

sales promotion (samples, coupons, discounts, premiums, souvenirs, joint advertising, etc.).

One of modern methods marketing cost planning is marginal marketing budget method. This approach assumes that the "elasticity of consumer response" varies with the intensity of marketing efforts. Such expenditure of funds for the use of each element of marketing, which leads to the greatest effect, is determined.

The product manager predicts the achievement of market share for a brand when various levels budget for advertising and promotion (budget unchanged, reduced budget, increased budget), as well as under various conditions of competition (normal level, increased activity of competitors, decrease in their activity). Calculations show that an increase in advertising spending will have the largest marginal impact on sales, regardless of the behavior of competitors. Reducing promotional costs will not adversely affect sales, and in the normal level of competition, even increase profitability. The manager decides to continue such calculations for several years in advance, while increasing the number options conditions of the market environment.

Marketing control

Marketing control is carried out at various stages with the help of individual elements of the control and analytical system. It includes:

situational analysis - a preliminary analytical stage of marketing planning, pursuing the goal of determining the position of the enterprise in the market. The analysis of the components of the external and internal marketing environment is used in the form of answers to pre-prepared groups of questions;

marketing control- the final stage of marketing planning, which aims to identify the compliance and effectiveness of the chosen strategy and tactics with real market processes. It is carried out in the form of strategic, current control and control of profitability using standardized forms;

marketing audit- the procedure for revising or significantly adjusting the strategy and tactics of marketing as a result of changes in conditions, both external and internal. Appropriate calculations and assessments are carried out;

marketing audit- analysis and evaluation of the marketing function of the enterprise. Carried out by specialists in the form of an independent external verification all elements of the marketing system. It is based on the general principles of the audit, aimed at identifying lost benefits from inadequate use of marketing in the enterprise. Represents a new direction in the field of marketing consulting. Uses generally accepted procedures management consulting(diagnosis, prognosis, etc.).

Strategic control

Strategic control is an assessment of strategic marketing decisions in terms of their compliance with the external conditions of the enterprise.

operational control

Operational (or current) control is aimed at assessing the achievement of the set marketing objectives, identifying the causes of deviations, their analysis and correction. The following indicators are monitored:

Sales volume (comparison of fact and plan);

Market share (change in competitive position);

The attitude of consumers to the enterprise and its products (surveys, conferences, examination, etc.).

The effectiveness of the use of funds allocated for marketing activities is also checked, for example: trade deals regarding commercial negotiations, the share of administrative expenses in the volume of sales, the cost of advertising and recognition by the consumer of the company's products, etc. Additional measures are being developed to improve the effectiveness of specific marketing activities.

Profit control

Profitability control is the verification of actual profitability across different products, markets, consumer or customer groups, distribution channels, and others as a result of implementing a marketing plan.

When controlling profitability, a distinction is made between direct and indirect marketing costs. Direct costs- these are costs that can be attributed directly to individual elements of marketing: advertising costs, commissions to sales agents, conducting questionnaire surveys, wage employees of the marketing service, payment for involved experts and specialists, etc. Such costs are included in the marketing budget in the relevant areas.

Indirect costs - these are the costs that accompany marketing activities: rental of premises, transportation costs, development technological processes and so on. Such costs are not directly included in the marketing budget, but can be taken into account during control, if necessary.

It is important to note that marketing costs cannot be unambiguously attributed to either production costs or consumption costs. These are costs of a special kind, which can rather be attributed to investment costs that work for the future.

Financial resources for marketing are deducted from the profit of the enterprise.

Findings and Conclusions

The marketing activity of the enterprise should be embodied in specific plan actions. Such a plan contains targets and means to achieve them in a certain period of time. At the same time, the marketing plan is considered as the most important component of the overall corporate plan and therefore is in close connection with the production, financial, marketing and similar plans of the enterprise.

Essential feature marketing plan is the fact that it is tool for continuous analysis, management and control, aimed at bringing the capabilities of the enterprise to the requirements of the market more fully, I

The development of a marketing plan (marketing process) includes several stages.

Marketing Opportunity Analysis in order to obtain a comprehensive understanding of the market conditions of activity ( external environment) and the real potential of the enterprise ( internal environment) to identify attractive directions in marketing efforts in the market.

Definition marketing goals, directly related to corporate goals. At the same time, marketing goals are formed as economic goals (sales volume and market share) and communication goals (by positioning).

Making strategic decisions, focused on the choice of ways to achieve the goals set based on the effective use of material, financial and labor resources enterprises. Marketing strategic decisions are made at the enterprise level and at the level of individual products and markets.

Development of a marketing plan on the product, prices, distribution, advertising and promotion, indicating specific deadlines, performers, costs, results.

Determination of Marketing Costs both in general and in individual events.

Plan control in the form of strategic, operational control and control of profitability, as well as subsequent, if necessary, adjustment of the plan, ensuring the unconditional achievement of the goals set.

Learning element № 5.

Which item of expenditure can be used to account for expenses: marketing services, information and consulting, etc.?

The article will explain in detail how to take into account the costs of marketing services and information and consulting services.

Question: Which item of expenditure can be used to account for expenses: marketing services, information and consulting, etc.? Is it possible to immediately write off the costs of current activities?

Answer: An organization may include marketing, information, consulting services as part of other expenses associated with production and sales at a time in the period to which they relate. In this case, the costs must be documented economically justified.

Almost every company has expenses for information, consulting or marketing services

Practice shows that most often tax authorities try to find schemes using overnight transactions in transactions related to the provision of information, consulting or marketing services. According to controllers, such services are often used to cover up illegal income tax optimization, unjustified VAT deductions, or for cashing out Money. Due to this tax authorities seek to prove the economic groundlessness of the expenses incurred, referring mainly to their inefficiency (decree of the Federal arbitration court West Siberian District dated 08/06/08 No. F04-4721 / 2008 (9200-A46-40), F04-4721 / 2008 (10739-A46-40).

It is clear that it is difficult for controllers to verify the reality of the execution of such agreements. However, despite the risky nature of such costs, companies often order such services. In particular, before concluding big deals or in complex litigation with partners.

Recall that, according to subparagraphs 14–19, 27 of paragraph 1 of Article 264 of the Tax Code, the costs of information, consulting and marketing services are other costs associated with production and sales. Wherein tax code RF does not establish a strict list of documents for business case expenses. According to Article 252 of the Tax Code of the Russian Federation, expenses can be confirmed by documents drawn up in accordance with Russian legislation or business practices, as well as documents indirectly confirming these expenses (for example, customs declaration, business trip order, travel documents, report on the work performed in accordance with the contract).

In order to prove during verification that business transactions with the counterparty were actually made, Special attention they devote to the preparation of primary documents: invoices, acts of work performed or services rendered, contractors' reports, transfer acts, invoices for payment, as well as invoices, technical specifications, applications, etc.

Under contracts for the provision of services, it is advisable to retain any documents and information to confirm that inherently intangible services were actually provided. These can be, for example, reports on the conducted market research, the provision of information services, the text of the consultation provided, printouts telephone conversations with the contractor, a memorandum based on the results of the consultation, etc.

Some companies compile an analytical report, which will additionally justify the need for "dangerous" services. Practice shows that such a document will facilitate the protection of expenses, even if there are no positive results of the services provided or the organization has structural units solving similar problems (for example, decisions of the federal arbitration courts of Moscow dated 01.24.08 No. KA-A40 / 14391-07, Far East court dated 04.21.08 No. F03-A04 / 08-2 / 264, dated 07.11.07 No. F03-A51 / 07-2 / 4297, West Siberian districts dated August 27, 2008 No. F04-2034 / 2008 (10781-A81-40).

The manual provides a list of required services. Indicate why they are needed and how the results obtained may affect economic activity companies. What problems may arise in the future if the issues remain unresolved.

For example, when purchasing consulting services manufacturing plant you can indicate what changes in performance are expected: an increase in the profitability of production, an increase in quality, output volumes finished products, improvement supply chain deliveries of products to consumers, etc. The companies also describe what risks are associated with the fact that the organization does not use the relevant services: positions in certain markets of the supplied products will be lost, export deliveries will be significantly reduced due to lower prices for similar products, supplied by competing organizations, etc.

In addition, the internal document of the company describes in detail the procedure for pricing, calculation of the expected time labor costs of the consultant (with time payment) and other expenses. This information can be obtained during preliminary negotiations with a representative consulting company. Be sure to include a list of questions that require answers.

In addition to competent documentation such high-risk transactions, companies prepare in advance a logical justification for the costs incurred. For example, in one case, a company stated in court that financial results its activity depends on the demand of the final consumer for the products. Since retailers do not track the preferences of brand consumers, and society has an interest in the product being purchased by the end consumer on an ongoing basis, marketing research costs are economically justified. The court accepted such arguments and canceled additional tax assessments (decree of the Federal Arbitration Court of the Moscow District dated July 15, 2010 No. KA-A40 / 7448-10-P-2).

In another case, the society brought another argument in its defense. Thus, monitoring current prices for products sold retailers, contributed to an increase in the demand of the end buyer, which ensured the uninterrupted sale of the company's products wholesale buyers. As a result, this led to timely price adjustments and contributed to the attraction of buyers, as well as the formation of a positive attitude towards trademark taxpayer and increase his profits (Resolution of the Federal Arbitration Court of the North-Western District dated January 27, 2010 No. A56-60357/2008).*

A way to justify the costs of consulting, marketing, management and intermediary services for income tax purposes

It is possible to recognize in tax accounting expenses for the acquisition of consulting, marketing, management and intermediary services without the risk of a tax dispute only by preparing evidence of their economic feasibility.

official position

In the opinion of regulatory authorities, if the results of consulting and other similar services are not specific and are not aimed at achieving real production goals, or if the list of services duplicates functional responsibilities full-time employees, the cost of such services cannot be taken into account when calculating income tax.

Rationale

Tax inspectors proceed from the fact that the absence of specific recommendations based on the results of the provision of services indicates that the costs incurred are not related to entrepreneurial activity. At the same time, "the connection of expenses with entrepreneurial activity is a key element for recognizing the costs incurred as economically justified expenses." Consequently, expenses that do not have such a connection do not reduce taxable income as economically unjustified and not aimed at generating income ( paragraph 1 of Art. 252 Tax Code of the Russian Federation). An immediate indicator of economic unreasonableness may be, for example, overview reports containing information about the general state of the market or the activities of other organizations that cannot be used to achieve specific production goals.

There are also court decisions that support the position of the regulatory agencies and on the issue of duplication of functions (decisions of the FAS Volga District dated April 3, 2007 No. A55-10037 / 2006-43 , of the East Siberian District of December 27, 2006 No. А19-6451/06-33-Ф02-6879/06-С1).

However, the courts are no less likely to support the taxpayer and indicate that “the absence of information on consultations and recommendations in the acts is not a circumstance that excludes the right to account for the costs of paying for services in the tax base” ( Decree of the Federal Antimonopoly Service of the Moscow District dated October 10, 2011 No. A40-30370 / 10-127-132). Also, the court may take into account the fact that the review report, which is not directly related to the activities of the organization, allows you to analyze the activities of enterprises in the industry as a whole and assess your own competitiveness in the market ( Decree of the Federal Antimonopoly Service of the North-Western District of November 21, 2006 No. A05-2732 / 2006-34).

If it is necessary to conclude an agreement on the terms of subscription services, the certificate must clearly define the scope and conditions for the provision of the relevant services. It is necessary to justify the payment of the established price based on the needs of the organization. If possible, it should indicate which consulting services will be provided in writing, and which are oral, that is, will not be documented. It is also important in the contract to give a clear description of the procedure for accepting the results: report formats, requirements for oral consultations.

Marketing services

Marketing services very often led to disputes with tax inspectors, who denied organizations the recognition of expenses for them. Therefore, the more detailed the contract for the provision of marketing services, the better. It should fix the deadlines, the obligation of the marketing company to submit a report on the work performed (). By general rule reporting is optional (see, for example, Decree of the FAS of the East Siberian District of March 1, 2007 No. A33-10956 / 06-F02-725 / 07). But due to the intangibility of services, the report is one of the main proofs of their reality.

The report should detail all the actions taken by the marketer, as well as conclusions and recommendations to the customer. At the same time, if the report does not comply with the terms of the contract, the inspectors may consider the costs unreasonable ( determination of the Supreme Arbitration Court of the Russian Federation dated March 19, 2008 No. 3741/08 , Decree of the FAS of the East Siberian District of February 12, 2008 No. A19-11279 / 07-50-F02-110 / 08).

The purpose of marketing research in without fail must match the business of the organization ().

An additional safety net can be a special order or order of the head of the organization, which will justify the need to purchase exactly this service. Example wording: “To make a decision to open a new retail store in the city of Podolsk, Moscow Region, I instruct the sales department to analyze the state of the market in this area. Information is required on the filling of the market with goods similar to those given in the list, as well as a forecast of sales in the first six months of the store's operation. For more accurate data, it is possible to contact professional marketing agencies.”

It is important to include in the contract for the provision of marketing services a condition that the provision of services is formalized by an act (, paragraph 2 of Art. 720 Civil Code of the Russian Federation).

The inspectors pay special attention to the further application of the results of marketing research (see, for example, Decree of the Federal Antimonopoly Service of the North-Western District of August 13, 2008 No. A05-5 / 2008). If the organization does not use the results of the ordered research in any way, does not adjust its activities according to the data received, then this increases the risk of claims.

In its work, the organization can use both positive and negative results of marketing research (FAS resolutions of the Northwestern District dated October 18, 2007 No. A56-1041 / 2007 , of the East Siberian District of May 29, 2006 No. А19-31699/05-15-Ф02-2421/06-С1). For example, after reviewing marketing reports, a manager may decide not to open new shop. You can confirm the use of marketing research, for example, in the form of a note from the head of the sales department addressed to CEO. Other local documents will help to prove that the organization has taken into account the results of the study in its activities - memorandums based on the results of meetings, etc. *

Management Services

sole functions executive body(manager) can be transferred to a third-party organization ( , paragraph 1 of Art. 69 of the Law of December 26, 1995 No. 208-FZ). Such an agreement will force the auditors to focus on two aspects: the cost of management services and the availability of staff performing duplicative functions.

In an agreement with a management company, it is safer to set a price in two parts: a fixed price, which is paid monthly, and a variable price, the basis for which will be the achievement of certain indicators by the organization. It is dangerous to increase the cost of services management company if there is no effect from management or the volume of its services remains the same. In this case, the court may consider the management costs unreasonable (see, for example, FAS rulings Volga District dated May 17, 2007 No. A65-39224 / 2005-CA1-37 , of the Urals District dated February 28, 2007 No. Ф09-1018 / 07-С3).

So, if services are not provided on a subscription basis and their cost varies from month to month, then it is better to justify such changes by the volume of services (for example, in man-hours), contractor's costs or other pricing indicators ( Decree of the Federal Antimonopoly Service of the Moscow District dated March 17, 2009 No. КА-А40/1737-09).

Performance reports should be as detailed as possible. There are court decisions positive for organizations even with careless completion of reports and acts of work performed ( determination of the Supreme Arbitration Court of the Russian Federation dated June 20, 2008 No. 7590/08). However, attention to these documents significantly increases the security of the transaction. It is desirable, although not necessary, to compile them monthly ( determination of the Supreme Arbitration Court of the Russian Federation dated November 28, 2007 No. 15254/07). The more carefully the report and the act are drawn up, the less reason the inspectors will have to point out the unreasonableness of management costs.

It is worth preparing other evidence of the participation of the management company in the activities of the organization. The presence of orders, orders of the representative of the management company will help confirm the fact of the provision of services. This will also be facilitated by various kinds of reports and reviews, indications in internal documents about the presence of representatives of the contractor at negotiations and business meetings, marks on documents on their agreement with the representative of the contractor, official correspondence, written responses and recommendations. This conclusion follows, for example, from Decree of the Federal Antimonopoly Service of the Volga-Vyatka District dated July 5, 2007 No. A82-9088 / 2006-14.

If possible, it is best to avoid situations where former leader goes to work in the management company. However, there is a positive arbitration practice. After all, the former manager, being an employee of the management company, provides services not only to his former employer, but also to other clients. Therefore, it is impossible to talk about the unreasonableness of expenses. This is mentioned, for example, in Decree of the FAS of the East Siberian District of April 25, 2006 No. A19-18184 / 05-40-Ф02-1722 / 06-С1.

The presence in the staff of employees duplicating the functions of the management company requires training additional justification for attracting a management company.

Intermediary services

For tax optimization, an agency agreement is often used, according to which the agent is instructed to find buyers or check their integrity. In this case, special attention should be paid to the design of the agent's report (). It should describe in as much detail as possible exactly what actions the intermediary performed. At the same time, it would be useful to mention in the internal documents of the organization about the involvement of an intermediary for certain actions. For example, in the final report of the sales department, you can analyze the performance of an agent.

If an intermediary performs trading operations, then the precautions will be somewhat different. The intermediary must be physically able to carry out the order. For example, storage facilities, as well as a sufficient number of employees with the necessary specialization. Otherwise, inspectors may question the reasonableness of the cost of an intermediary.

It will be necessary to justify why an intermediary is needed, especially if the organization has a staff of employees who sell goods, works, services, and also has an established sales market.

If the intermediary resells the goods, it is safer if its accounting reflects the costs of transport and handling services. After all, inspectors can demand documents confirming the transaction, both from the organization being checked and from its counterparties (Article 93.1 of the Tax Code of the Russian Federation

“CCP should be used only in cases where the seller provides the buyer, including its employees, with a deferral or installment plan for paying for their goods, works, services. It is these cases, according to the Federal Tax Service, that relate to the provision and repayment of a loan to pay for goods, work, and services. If an organization issues a cash loan, receives a return of such a loan, or itself receives and repays a loan, do not use the cash desk. When exactly you need to punch a check, see the recommendations.