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COVID-19 Zwolnienia z obowiązku opłacania składek ZUS nie podlegają opodatkowaniu

Warto pamiętać, że zwolnienia z obowiązku opłacania składek (umorzenia składek ZUS) nie stanowią przychodu firmy w rozumieniu przepisów o podatku dochodowym od osób fizycznych (PIT) oraz przepisów o podatku dochodowym od osób prawnych (CIT). W związku z tym przychody te nie podlegają opodatkowaniu podatkiem dochodowym. Takie rozwiązanie zostało przyjęte w art. 31zx ustawy COVID-19.
W interpretacji poselskiej (nr 6061), posłanki Barbary Dolniak możemy przeczytać, że tarcza antykryzysowa 1.0 wprowadzona z końcem marca 2020 r. zakładała szeroko zakrojoną pomoc dla mikro-, małych oraz średnich przedsiębiorców. Wśród pakietu pomocowego znalazła się również możliwość umorzenia składek ZUS za okres marzec-maj 2020 r. Jej zdaniem, nikt jednak z rządzących nie wziął pod uwagę okoliczności, iż umorzenie składki ZUS za konkretny miesiąc powoduje wzrost podatku dochodowego danego przedsiębiorcy. Tym samym przedsiębiorcy, wobec których umorzono składki ZUS za okres marzec-maj 2020 r., w rzeczywistości kwotę, którą opłaciliby składkę, oddadzą państwu w postaci podatku dochodowego w każdym jednym miesiącu, w którym korzystają z umorzenia w ZUS-ie.

We wspomnianej interpetacji, chciała dowiedzieć się czy Ministerstwo Finansów przewidziało narzędzia, które spowodują, iż brak opłacenia składki w ZUS nie spowoduje wzrostu podatku dochodowego przedsiębiorcy.
Jeśli tak, to o jakich narzędziach mowa?
Jeśli nie, to z jakich powodów?
Czy Ministerstwo Finansów planuje wprowadzenie do pakietu pomocowego dla przedsiębiorców możliwości nieopłacania podatku dochodowego za okres marzec-maj 2020 r. na wzór umorzenia składek ZUS w tożsamym okresie?

Ministerstwo Finansów wyjaśniło:
Należy mieć na uwadze, że aby przedsiębiorca (osoba fizyczna) mógł odliczyć, albo zaliczyć do kosztów uzyskania przychodów składki na ubezpieczenie społeczne, musi te składki zapłacić. Obowiązujące przepisy stanowią, iż składki na ubezpieczenia społeczne, zgodnie z art. 26 ust. 1 pkt 2 oraz art. 30c ust. 2 ustawy PIT1, pomniejszają podstawę obliczenia podatku, ale tylko jeżeli zostały faktycznie zapłacone w roku podatkowym. Tym samym w przypadku zwolnienia z opłacania składek na własne ubezpieczenie społeczne nie ma podstaw, żeby ich wysokość była odliczana od podstawy opodatkowania. Podobnie w przypadku zaliczenia tych składek do kosztów uzyskania przychodów. Tylko faktycznie zapłacone składki mogą być kosztem uzyskania przychodów.

Podsumowując. Dla przedsiębiorców, którzy z uwagi na sytuację gospodarczą nie osiągają dochodów lub ponoszą straty, zwolnienie z obowiązku płacenia składek na ubezpieczenie społeczne i zdrowotne oznacza poprawę ich sytuacji finansowej, ponieważ nie ponoszą wydatku z tytułu opłacania tych składek.
Zabezpieczeniem przed wzrostem obciążeń przedsiębiorcy podatkiem dochodowym jest rozwiązanie przyjęte w art. 31zx ustawy COVID-192. W związlku z tym, w świetle tej regulacji przychody z tytułu zwolnienia z obowiązku opłacania składek nie stanowią przychodu w rozumieniu przepisów o podatku dochodowym od osób fizycznych oraz przepisów o podatku dochodowym od osób prawnych. Zatem przychody te nie podlegają opodatkowaniu podatkiem dochodowym.

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