Заява щодо змін до Податкового кодексу України в частині комісійної винагороди страховим посередникам

За результатами опрацювання пропозицій народних депутатів до проекту Закону «Про внесення змін до Податкового кодексу України та деяких інших законодавчих актів України щодо покращення адміністрування та перегляду ставок окремих податків і зборів»  р.№ 9260 в частині оподаткування комісійної винагороди страховим посередникам, а саме збільшення фінансового результату до оподаткування страховика на позитивну різницю між сумою комісійної винагороди, сплаченої посередникам та іншим особам і розміром такої винагороди, що буде визначено Нацкомфінпослуг за погодженням Мінфіном (доповнення ПКУ новим підпунктом 14.1.1251 та новим абзацом третім підпункту 141.1.3 пункту 141.3 статті 141) зауважуємо наступне.

При підготовці таких суттєвих змін до податкового законодавства у сфері страхування слід дотримуватися принципу передбачуваності, згідно з яким зміни готуються заздалегідь, обґрунтовуються належним чином та обов’язково обговорюються з учасниками ринку. Недотримання цього принципу майже завжди призводить до неочікуваних наслідків для всіх учасників ринку.

Щодо суті запропонованих змін, вважаємо що такі зміни є нічим іншим, як втручанням в господарську діяльність страховиків, їх прийняття спричинить зміну бізнес-моделей страховиків та матиме непрогнозовані наслідки для ринку. На нашу думку, вони не дадуть позитивного результату, але, водночас, посилять адміністративний тиск на класичний бізнес та збільшать ризики корупції

Запропоновані зміни в оподаткуванні операцій зі страховими посередниками та іншими особами, що надають послуги щодо укладання (пролонгації) договорів страхування, нажаль підготовлені без дотримання принципу передбачуваності, на відміну від пропозицій УФУ до ПКУ щодо особливостей оподаткування страховиків, які майже в повному обсязі були враховані та запроваджені з 2015 року і які показали свою ефективність як для класичного страхового ринку, так і для бюджету країни.

З того часу були неодноразові спроби змінити податкове законодавство в частині оподаткування страховиків, але ці спроби були невдалими, зокрема, завдяки і нашим запереченням.

Враховуючи викладене, УФУ категорично заперечує проти такого підходу до формування законодавчого поля та внесення зазначених змін до Податкового кодексу України,  негативні наслідки яких непередбачувані.

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