Performing commissioning work.  Commissioning and commissioning.  Commissioning of ventilation systems: features

Performing commissioning work. Commissioning and commissioning. Commissioning of ventilation systems: features

During the implementation of many projects, capital construction or reconstruction of buildings and structures is carried out with the installation of new equipment or specialized processes. Such works include the installation of fire extinguishing systems, power supply, air conditioning, ventilation, fire alarms. All of them require commissioning, for this, a commissioning program has been drawn up more and more often lately.

What is NDP and why they are carried out

According to SNiP, commissioning is a set of activities that are carried out during the preparation for the implementation of integrated testing and individual testing of installed equipment. This includes checking, testing and adjusting equipment to achieve design parameters.

The performance of all these manipulations is usually carried out on a contractual basis by specialized organizations that have the necessary permits and a staff of qualified specialists. The necessary conditions for their activities at the site (industrial sanitation, labor safety) are organized by the customer, who also pays for commissioning at the expense of the general estimate for putting the facility into operation. All operations must be carried out by instructed and certified for each specific case by the personnel of the commissioning organization under the supervision of a responsible representative on the part of the customer.

There are two main stages in the commissioning activities:

  • Individual tests are activities that are designed to ensure that the requirements that are provided for by specifications, standards and working documentation, for testing units, machines and mechanisms. The purpose of individual tests is to prepare for complex testing in the presence of a working commission.
  • Complex tests are actions carried out after the acceptance of the mechanisms by the working commission, and directly the complex testing itself. At the same time, the interconnected joint operation of all installed equipment is checked at idle, then under load, after which the technological regime provided for by the project is reached.

Although not mandated by law, last years more and more often, the customer requires that a commissioning program be drawn up for testing work. This gives confidence that not a single nuance will be missed, and the operation of all systems will comply with the approved standards and project documentation.

How is it compiled and what does the commissioning program include?

The commissioning program is a document that clearly outlines the entire list of actions that will be carried out by the responsible organization. On the net, you can see discussions about whether it is worth including a commissioning methodology in the Program or whether it should be drawn up as a separate document. There are no clear requirements regarding this, so everything here depends on the agreements of the parties. A sample for each specific situation can be easily found on the Internet.

The program is drawn up and approved by a representative of the commissioning company and agreed by the customer, the signatures and seals of the parties are put in the header of the document. The following sections follow (as an example, let's take the preparation of a hotel heating system):

  • checking the correctness of installation, readiness and serviceability of equipment in visual mode (control devices, valves, filling the system with water), following the results, a defective list is compiled;
  • commissioning tests in operating conditions, balance experiments (setting optimal modes, testing valve control in manual and automatic modes, checking automation settings, identifying shortcomings and working out proposals for their elimination), the result is an act of individual tests;
  • comprehensive testing (72 hours of continuous operation for all main equipment, 24 hours for heating networks), its beginning is considered to be the time when all systems are started at maximum load.

Some companies document all activities related directly to the preparation and testing of devices in a separate document - the Commissioning Methodology, which comes as an addition to the Program. In the Program, they include more general things of an organizational nature. That is, there is an actual division of the entire complex of works into organizational, legal and technical components. However, the Methodology is often an integral part of the main body of the approved Program.

An integral part of the Program may be such additional documents:

  • passports of ventilation, heating and hot water supply systems, as well as individual nodes of their connection;
  • the procedure for preparing and subsequent commissioning with a list of all operations, their start and end times;
  • list of stationary and portable measuring instruments (pressure gauges, thermometers, etc.);
  • list of control and stop valves, equipment (pumps, valves, heat exchangers, filters);
  • list of control points and measurement protocol for each of them;
  • a list of parameters that require clarification and adjustment (humidity and air temperature, pressure in pipes, coolant flow rates);
  • a method for measuring heat losses by building structures (a special act is drawn up and a certificate is issued).

After the completion of all commissioning works, complex testing and regime tests, a commissioning report is drawn up with the relevant annexes (a list of mechanisms and equipment on which adjustment and testing was carried out).

The technical report of the involved specialized organization issues, as a rule, within one month.

Commissioning works (NDP)- a set of works performed during the preparation and conduct of individual tests and comprehensive testing of equipment.

Finer and more detailed adjustment work performed on the installed equipment before commissioning.

They are the final part of the construction installation work(CMP).

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    ✪ Commissioning: preparation and stages of implementation

    ✪ Calculation of estimate documentation for commissioning of process control systems

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Poland in construction

Poland in mechanical engineering

Poland in the electric power industry

Commissioning, accompanying electrical work, is a set of works, including checking, setting and testing electrical equipment in order to ensure its design parameters and modes. Carried out in four stages:

First (preparatory) stage

  • The contractor develops (based on the design and operational documentation of manufacturers) a work program for commissioning, including labor protection measures; transfers to the customer the comments on the project identified during the development process work program; prepares a fleet of measuring equipment, test equipment and fixtures.
  • The customer issues to the contractor the settings for relay protection, interlocks and automation, agreed with the power system; supplies voltage to the workplaces of adjustment personnel from temporary or permanent power supply networks; appoints representatives for the acceptance of commissioning works and agrees with the contractor on the deadlines for the completion of work, taken into account in the general construction schedule.

Second phase

  • Adjustment work is carried out on separate control panels, protection and automation, as well as adjustment work combined with electrical installation work. The start of commissioning works is determined by the degree of readiness of construction and installation works: in electrical rooms, all construction works, including finishing, all openings, wells and cable channels are closed, lighting, heating and ventilation are completed, the installation of electrical equipment is completed and its grounding is completed.
  • The general contractor provides temporary power supply and temporary communication in the work area. The customer provides:

coordination with the design organization of issues on the comments identified in the process of studying the project;

  • Architectural supervision by design organizations;
  • Replacement of rejected and supply of missing electrical equipment, elimination of defects in electrical equipment and installation identified in the process of commissioning;

verification and repair of electrical measuring instruments.

At the end of the second stage of commissioning and before the start of individual tests, the contractor makes changes to the circuit diagrams of power supply facilities that are switched on under voltage.

Third stage

  • Individual tests of electrical equipment are carried out, in particular, testing and testing of cooling systems and on-load tap-changers of transformers, protection devices, automation and equipment control, especially with new relays from Siemens and ABB.
  • The introduction of the operating mode at this electrical installation, after which commissioning should be related to work in existing electrical installations and be carried out with the issuance of a work permit and compliance with technical and organizational safety measures.
  • Individual testing of equipment, setting of parameters, protection settings and equipment characteristics, testing of control, protection and signaling circuits, as well as testing of electrical equipment at idle are carried out.
  • After the completion of individual tests, the electrical equipment is considered accepted for operation. At the same time, the contractor transfers to the customer the protocols for testing electrical equipment with increased voltage, checking grounding and grounding devices, as well as executive and circuit diagrams necessary for the operation of electrical equipment. All other protocols for the adjustment of electrical equipment are transferred to the customer within four months after the acceptance of the facility into operation. Completion of commissioning at the third stage is documented by an act of technical readiness of electrical equipment for comprehensive testing.

Fourth stage

  • Comprehensive testing of electrical equipment is carried out according to approved programs.
  • Commissioning is being carried out to set up the interaction of electrical equipment systems in various modes. These works include:
    • provision of interconnections, adjustment and adjustment of the characteristics and parameters of individual devices and functional groups of the electrical installation in order to ensure the specified operating modes on it;
    • testing of the electrical installation according to the full scheme at idle and under load in all modes of operation in order to prepare for a comprehensive testing of process equipment.

Commissioning at the fourth stage is considered completed after the electrical equipment receives the parameters and modes provided for by the project, which ensure a stable technological process. For power transformers, this is 72 hours of operation under load, for air and cable lines power transmission - 24 hours of operation under load.

"Industry: accounting and taxation", 2011, N 6

In what cases are the costs of commissioning work forming the cost of depreciable property, and in which cases are they recognized at a time? What documents can confirm the validity of the expenses incurred? How to prove the non-capital nature of commissioning?

The concept of commissioning

Commissioning works by nature and purpose are a continuation of installation work and the final link in new construction, as well as reconstruction, expansion and technical re-equipment of existing enterprises, buildings and structures. Upon completion of commissioning, the object can be presented for commissioning. The main provisions on the procedure for commissioning are set out in SNiP 3.05.05-84<1>.

<1>SNiP 3.05.05-84 "Technological equipment and technological pipelines", approved by the Decree of the USSR State Construction Committee of 05/07/1984 N 72.

Commissioning includes a set of works performed during the preparation and conduct of individual tests and comprehensive testing of equipment. At the same time, the concept of "equipment" covers the entire technological system of the facility, that is, a complex of technological and other types of equipment and pipelines, electrical, sanitary and other devices, automation systems that ensure the release of the first batch of products provided for by the project.

So, commissioning is a set of works on checking, testing and setting up equipment in order to ensure the specified operating parameters. The tasks of commissioning are to identify possible errors in design and construction and installation works, to detect shortcomings in the operation of equipment before it is put into operation. Prior to the start of individual testing of the installed equipment, commissioning works are carried out according to electrical devices, automated systems control, heat power and some other types of equipment, the implementation of which ensures individual testing of process equipment - the final stage of the installation of this equipment. Commissioning works, which are carried out during the period of individual testing of equipment, ensure the fulfillment of the requirements stipulated by the working documentation, standards and specifications for individual machines, mechanisms, devices and units, in order to prepare the equipment for acceptance by the working commission for comprehensive testing. During the period of complex testing of the equipment, checks, adjustments and ensuring the joint interconnected operation of the equipment in the technological process provided for by the project at idle are carried out, followed by the transfer of the equipment to work "under load" and the conclusion to a stable technological mode, ensuring the release of the first batch of products.

Requirements for the conduct and acceptance of commissioning work on devices, systems and equipment are given in part 3 of the SNiP for the relevant types of installation work. At the same time, the composition of commissioning works and programs for their implementation must comply with the requirements specifications enterprises - manufacturers of equipment, the rules of labor protection and safety, fire safety.

Commissioning works are carried out in three stages: preparatory work; individual tests; complex testing of installations. At run time preparatory work the operating documents for the equipment should be studied, the workplaces of the adjusters should be provided with the necessary inventory and auxiliary technical means. At the stage of individual testing, work is carried out to set up, adjust the equipment in accordance with their technical descriptions, instructions, etc. Individual tests are carried out during the installation work. The stage of complex testing is carried out after the completion of all installation work. At this stage, adjustments to the previously carried out adjustment of the equipment, bringing all the equipment to the operating mode and checking the interaction of the equipment should be made.

Costs for preparation and development of production

The Tax Code does not regulate the procedure for recognizing expenses for commissioning. Meanwhile, the Tax Code of the Russian Federation makes it possible to attribute to other expenses associated with production and sale the expenses for the preparation and development of new enterprises, industries, workshops and units. The basis - paragraphs. 34 p. 1 art. 264 of the Tax Code of the Russian Federation. The content of the group of expenses of this subparagraph is not specified. The main provisions for planning, accounting and calculating the cost of production for industrial enterprises <2>(hereinafter referred to as the Basic Provisions), the costs of preparing and developing production are allocated in a separate calculation item (clause 31), which groups, in particular, the costs of developing new enterprises, industries, workshops and units (start-up costs) and the costs of preparing and mastering the production of new types of products and new technological processes. Clause 5 of the Basic Provisions explains what is meant by start-up costs: the costs of checking the readiness of new enterprises, industries, workshops and units for their commissioning by comprehensive testing (under load) of all machines and mechanisms (trial operation) with a trial release of the envisaged product design, equipment adjustment. It also clarifies that they do not relate to start-up costs and are reimbursed from funds allocated for capital investments, in particular, the costs of individual testing of certain types of machines and mechanisms and for complex testing (idle) of all types of equipment and technical installations in order to check the quality of their installation.

<2>Approved by the State Planning Committee of the USSR, Goskomtsen of the USSR, the Ministry of Finance of the USSR, the Central Statistical Bureau of the USSR on 07/20/1970.

The foregoing allows us to conclude that the costs of commissioning, carried out during the period of complex testing of equipment ("under load") with trial production, are included in the start-up costs, taken into account on the basis of paragraphs. 34 p. 1 art. 264 of the Tax Code of the Russian Federation. Start-up costs do not include the costs of commissioning carried out at the stages of preparation and individual testing of equipment.

Commissioning works "idle" and "under load" in the construction estimate

The current procedure for attributing the costs of commissioning in the construction estimate documentation is established by the Ministry of Regional Development in Letter No. BT-386/08 dated 13.04.2011. This order is different for production and non-production purpose.

During the construction of new, reconstruction and technical re-equipment of existing housing and civil, social, as well as special-purpose facilities that are not related to the production of products (with income from its sale), all costs for commissioning necessary to bring the facility to a condition suitable for use, and carried out before the commissioning of the facility and the formation of the initial cost of depreciable property (fixed assets), are included in Ch. 9 "Other work and costs" (columns 7 and 8) of the summary estimate calculation of the cost of construction without division into work performed "idle" and "under load". At the same time, the composition and volume of commissioning work performed must comply with the requirements of the project, SNiP, technical regulations, technical documentation of equipment manufacturers, other regulatory and technical documentation of bodies state control and supervision, rules of technical operation and safety.

Start-up costs for production facilities must be taken into account in accordance with paragraph 4.102 of the Methodology for determining the cost construction products within the territory of Russian Federation(MDS 81-35.2004<3>). According to this norm, the costs of commissioning:

  • "idle" - are included in Ch. 9 "Other work and costs" (columns 7 and 8) of the summary estimate;
  • "under load" - can be treated as non-capital expenses for the estimated cost that will be incurred (provided) during the operation of the constructed facilities, and, as a rule, are not provided for in the estimate documentation for construction.
<3>Approved by the Decree of the Gosstroy of Russia dated 05.03.2004 N 15/1.

With the release of the Letter of the Ministry of Regional Development of Russia dated 13.04.2011 N VT-386/08, the clarifications given in the Letter of the Gosstroy of Russia dated 10.27.2003 N NK-6848/10 became invalid. The latter provided for the procedure for attributing and accounting for the costs of commissioning in the estimate documentation developed from 01.11.2003. This procedure was agreed with the Ministry of Finance of Russia, the Ministry of Taxes of Russia and the Ministry of Economic Development of Russia and remained unchanged until its cancellation.<4>. As Gosstroy explained, the costs of commissioning "idle", associated with bringing the object to a state suitable for use, in accordance with the norms of Art. 257 of the Tax Code of the Russian Federation are accounted for as capital expenditures. The cost of commissioning "under load", carried out after the initial cost of depreciable property (fixed assets) is formed, in accordance with paragraphs. 34 p. 1 art. 264 of the Tax Code of the Russian Federation as non-capital expenses are accepted for tax accounting as part of other expenses associated with production and sales, and are financed from the main activities of the operating organization. The cost of commissioning "idle" was included in Ch. 9 "Other work and costs" (columns 7 and 8) of the summary estimate of the cost of construction. When attributing the costs of commissioning "idle" to capital investments, one should be guided by the Structure of the full range of commissioning works, taken into account in the new budget and regulatory framework 2001, developed by Gosstroy, in accordance with the Appendix to Letter N NK-6848/10. The final part of the Letter contained a reservation: the procedure for attributing costs for commissioning works is valid for the construction of new, expansion, reconstruction and technical re-equipment of existing enterprises, buildings and structures for housing, civil and industrial purposes. In other words, the procedure for financing commissioning works, intended for industrial facilities, was also extended to civil housing facilities. Actually, for non-production facilities that are not related to the production of products, the division of commissioning work into work "idle" and "under load" was meaningless: at what expense should the costs of performing work "under load" be compensated if the product is not produced and not implemented? The Ministry of Regional Development previously noted that the entire range of commissioning works carried out in relation to non-production facilities is covered by the concept of “idle” work (Letter of 09.10. start-up costs in construction estimate in relation to non-production objects.

<4>Letter of the Ministry of Regional Development of Russia of October 13, 2009 N 33499-IP / 08.

Recognition of expenses for commissioning in tax accounting

Explaining the procedure for accounting for the costs of commissioning, financiers rely on the Letter of the Gosstroy of Russia N NK-6848/10<5>. In Letter N 03-03-06/2/148 dated 07.08.2007, the Ministry of Finance reported that the said Letter of the State Construction Committee distinguishes between accounting for the costs of commissioning "idle" and "under load":

  • the cost of carrying out "idle" work is included in the summary estimate of the cost of construction as capital expenditures and are integral part the initial cost of the fixed asset under construction;
  • the cost of performing work "under load" is not included in estimate documentation and are included in other expenses as non-capital expenses.
<5>At the time of the clarification, it was it that was in force, and not the Letter of the Ministry of Regional Development of Russia N BT-386/08.

In the Letter dated 02.11.2010 N 03-03-06 / 1/682, the Ministry of Finance indicated: non-capital expenses associated with the preparation and development of new production, which, in accordance with paragraph 1 of Art. 257 of the Tax Code of the Russian Federation are not taken into account in the initial cost of fixed assets, are included in other expenses associated with production and sales, on the basis of paragraphs. 34 p. 1 art. 264 of the Tax Code of the Russian Federation. Expenses for commissioning "under load", carried out after the initial cost of depreciable property (fixed assets) is formed, as non-capital expenses are accepted for tax accounting as part of other expenses associated with production and sales, in accordance with paragraphs. 34 p. 1 art. 264 of the Tax Code of the Russian Federation. In the event that the initial cost of the fixed asset is not formed, the costs of commissioning as costs associated with bringing the fixed asset to a state in which it is suitable for use, on the basis of paragraph 1 of Art. 257 of the Tax Code of the Russian Federation are taken into account in the initial cost of this fixed asset.

Similarly, in the Letters of the Ministry of Finance of Russia dated 04.20.2006 N 03-03-04/1/363, dated 08.24.2004 N 03-03-01-04/1/9 it is explained that the cost of commissioning "idle" does not reduce the taxable profit as current expenses of the organization, but are included in capital costs and for the purposes of profit taxation (that is, they are included in the initial cost of fixed assets and are taken into account in expenses as part of depreciation), and for the purposes of accounting, and for statistical purposes. Expenses for commissioning "under load", carried out after the initial cost of depreciable property (fixed assets) has been formed, are accepted for tax accounting as expenses of a non-capital nature as part of other expenses associated with production and (or) sales, in in accordance with paragraphs. 34 p. 1 art. 264 of the Tax Code of the Russian Federation. The same procedure for accounting for expenses for commissioning "under load" is indicated by the Ministry of Finance in Letter No. 03-03-06/1/495 of July 28, 2009. In the Letter of the Ministry of Regional Development of Russia dated 07.04.2010 N 13149-IP / 08 it is noted: if the generator engine is run-in during the period of individual equipment tests (before acceptance by the working commission), the costs of the necessary material resources are taken into account as capital expenditures. Price material resources required for running in the generator engine, carried out during the period of complex testing of the equipment (after acceptance by the working commission), is not included in capital investments. These are the running costs of the organization.

Taxpayers applying the accrual method recognize the costs associated with the preparation of proceedings in the period in which they were made, on the basis of paragraph 1 of Art. 272, paragraph 2 of Art. 318, paras. 34 p. 1 art. 264 of the Tax Code of the Russian Federation (Letters of the Ministry of Finance of Russia of 06.09.2007 N 03-03-06 / 1/646, of 10.07.2003 N 04-02-05 / 1/72).

Since the procedure for recognizing start-up costs proposed by officials is not spelled out in tax code cannot be called indisputable. After analyzing the arbitration practice, we single out individual judicial acts, in which the approach of officials to the procedure for accounting for commissioning costs is refuted. Thus, the FAS MO in its Decree of 11.07.2008 N KA-A40 / 5083-08-2 indicated that from the norm of paragraphs. 34 p. 1 art. 264 of the Tax Code of the Russian Federation does not follow that the cost of commissioning can be attributed to other expenses only in the case of work "under load". Therefore, any costs for commissioning work (both "on load" and "idle") are accounted for as other expenses in the tax period in which they were incurred. In Resolution No. 09AP-18689/2009-AK dated October 12, 2009, the Ninth Arbitration Court of Appeal upheld the taxpayer, who recognized the costs of commissioning and testing new equipment as current (rather than capital) expenses, justifying this as follows. A special rule (clause 34, clause 1, article 264 of the Tax Code of the Russian Federation) singles out the costs of preparing and developing new industries, workshops and units as a separate group of expenses. These costs are subject to one-time write-off as part of current costs by virtue of paragraphs. 3 p. 7 art. 272 of the Tax Code of the Russian Federation and, therefore, are not subject to attribution to the initial cost of the fixed asset in accordance with paragraph 2 of Art. 257 of the Tax Code of the Russian Federation. The disputed costs in their content corresponded to the concept of expenses for preparation and development and were lawfully taken into account by the taxpayer in accordance with paragraphs. 34 p. 1 art. 264 of the Tax Code of the Russian Federation. In the Decree of 06.02.2008 N 09AP-16922 / 07-AK<6>The Ninth Arbitration Court of Appeal also noted that the costs of preparing and developing new industries, workshops and units are separated into an independent group and therefore are subject to inclusion in other expenses in accordance with a special rule (clause 34 clause 1 article 264 of the Tax Code of the Russian Federation), and not in the initial cost of fixed assets. According to the arbitrators, if the cost of commissioning can be characterized as the cost of mastering production, workshops and units, they are current, regardless of whether they are related to bringing the OS object to a state suitable for operation. At the same time, the costs of checking the readiness of equipment brought to a state suitable for operation for commissioning through its comprehensive testing are not capital. If the start-up costs cannot be characterized as expenses for the development of production, workshops and units, it is necessary to establish whether they are associated with bringing the fixed asset to a state suitable for operation, and, depending on this, determine the nature of the costs (current or capital). The court concluded that the provisions of paragraph 1 of Art. 257 of the Tax Code of the Russian Federation does not establish that all expenses incurred before the execution of the act of putting the facility into operation, are capital and are subject to inclusion in the initial cost of fixed assets. Based on this rule, the arbitrators concluded that the costs of an object that is already ready for operation cannot be of a capital nature. The court considered that the commissioning work carried out by the taxpayer in relation to facilities that are already ready for operation and aimed at checking the equipment being put into operation, adjusting and checking the readiness of facilities for operation, did not change the degree of readiness of facilities for operation, which means that the costs of such work can be taken into account at the same time.

<6>Left unchanged by the Decree of the FAS MO dated 20.05.2008 N KA-A40 / 4099-08-P.

Let's sum up the intermediate result. There are two positions on the issue of accounting for start-up costs. The first (official) is that the cost of commissioning "idle" is taken into account in the initial cost of the fixed asset, and the cost of work "under load" - these are other expenses recognized in the tax (reporting) period in which they are produced. The second point of view is that the cost of performing any commissioning work (both "idle" and "under load") is accounted for as current. The taxpayer who chooses the second position is more likely to cause complaints from controllers.

We confirm the non-capital nature of expenses

So, the company decided to recognize the costs of commissioning as recommended by officials, that is, to divide them into capital and non-capital. Let us name the most important signs of non-capital expenditures.

  1. Non-capital works are carried out after the initial cost of the OS object is finally formed. The final cost of the fixed asset is determined by the time it is put into operation, because:
  • in accounting, the posting Debit 01 Credit 08 is drawn up when the object is accepted for operation (Instructions for the application of the Chart of Accounts);
  • in tax accounting, the object is included in the depreciable property at the time of its commissioning (which is confirmed by the relevant act) (clause 4, article 259 of the Tax Code of the Russian Federation).

Thus, the costs of commissioning carried out before putting the equipment into operation are taken into account in its initial cost, and after putting it into operation, they are taken into account as other expenses on the basis of paragraphs. 34 p. 1 art. 264 of the Tax Code of the Russian Federation (Resolution of the FAS VSO dated March 10, 2006 N A33-22400 / 04-C3-F02-858 / 06-C1).

  1. Non-capital works are aimed at comprehensive testing ("under load") of all machines and mechanisms (for trial operation) with trial production. In Decree N A35-5033 / 08-C21 of February 18, 2010, the Federal Antimonopoly Service of the Central Organ named the distinctive features of the costs that form the initial cost of the fixed asset (clause 1, article 257, clause 5, article 270 of the Tax Code of the Russian Federation), and the costs of preparing and developing production (clause 34 clause 1 article 264 of the Tax Code of the Russian Federation). The first ones are aimed at the formation of a specific object and its subsequent bringing to a state suitable for use, but no release finished products , the latter are associated with the production and sale of finished products, and therefore do not affect the cost of the fixed asset used in each specific case, but are included in the cost of manufactured products. In other words, if the organization carries out a comprehensive testing, preparation and development of new production with simultaneous release of finished products(commissioning "under load"), the corresponding costs are to be included among the other costs associated with the production of products. These costs are indirect and form tax base current tax period. But checking the readiness of equipment for the release of products, during which testing, launching, testing of equipment without the release of finished products ("idle"), corresponds to the concept of "bringing the equipment to a state in which it is suitable for use", and the costs incurred by the taxpayer for these purposes, are subject to attribution to the cost of fixed assets. In Decree N А19-12474/06-50-Ф02-210/07 dated 22.02.2007 N А19-12474/06-50-Ф02-210/07, the FAS VSO established that the organization checked the readiness of production through comprehensive testing ("under load") of all machines and mechanisms with trial production. The arbitrators recognized that the taxpayer's expenses are related to the development of new production and, accordingly, are related to other expenses by virtue of paragraphs. 34 p. 1 art. 264 of the Tax Code of the Russian Federation, and are not the costs of bringing the object to a state in which it is suitable for use, as insisted tax authority. In Decree N КА-А40/3877-09 dated 10.06.2009 FAS MO sided with the taxpayer, who took into account the costs of commissioning the unit as non-capital expenses. After examining the contracts for commissioning and acts of work performed, as well as evidence of the release of finished products during the performance check of the unit, the arbitrators came to the conclusion that the commissioning was not related to the testing work, but was the additional adjustment of the equipment during its commercial operation, were carried out after the formation of the initial cost of fixed assets. This means that the costs of such work are rightfully attributed to other expenses in accordance with paragraphs. 34 p. 1 art. 264 Tax Code of the Russian Federation<7>.
<7>See also Ruling of the Ninth Arbitration Court of Appeal dated March 11, 2008 N 09AP-1307/2008-AK.

Carrying out a comprehensive testing of equipment "under load", but before its commissioning

We found out that if an enterprise carried out commissioning work after putting the equipment into operation and these works were aimed at comprehensive testing (“under load”) of all machines and mechanisms with trial production, then commissioning costs are taken into account as other expenses. But what if the company spent commissioning "under load" before putting the equipment into operation(and, accordingly, before the issuance of an act in the form of N OS-1, which, according to the Instructions for the use and filling out forms of primary accounting documentation accounting for fixed assets<8>used to include objects in fixed assets and account for their commissioning)? Is it possible in this case to recognize the costs of commissioning as part of other expenses (clause 34, clause 1, article 264 of the Tax Code of the Russian Federation)? Or is it necessary to increase the initial cost of the OS object on them? Tax officials, of course, insist on the second option for recognizing expenses. However, one can argue with them. From paragraphs 1, 3, 6 of Appendix 1 to SNiP 3.05.05-84, paragraph 1.5 of SNiP 3.01.04-87<9>it follows that commissioning for integrated testing in operating modes ("under load") is carried out after the equipment is accepted by the working commission and before it is accepted into operation by the state acceptance commission, that is, before the equipment is put into operation. The conclusions of the arbitrators will help to argue the legitimacy of a one-time recognition of the costs of commissioning "under load" before the equipment is put into operation. Let us turn to the Decree of the FAS PO of January 15, 2009 N A55-5612 / 2008. The taxpayer included in the expenses of the current period the costs of commissioning of equipment with the release of finished products (more than 517 million rubles), carried out after the signing of equipment acceptance certificates by the working commission, but before the acceptance of the equipment by the state acceptance commission. FAS PO noted that checking the readiness of equipment for production, during which testing, launching, testing of equipment without the release of finished products, meets the concept of "bringing the equipment to a state in which it is suitable for use" within the meaning of paragraph 1 of Art. 257 of the Tax Code of the Russian Federation, therefore, the expenses incurred by the taxpayer for these purposes are subject to attribution to the cost of fixed assets. And on the basis of par. 34 p. 1 art. 264 of the Tax Code of the Russian Federation, if the organization carries out comprehensive testing, preparation and development of new production with simultaneous release of finished products (commissioning work "under load"), the costs associated with the development of new production and trial production during the commissioning period are to be included in the number costs associated with the production of finished products. These expenses are indirect and form the tax base of the current tax period. In addition, based on clause 1.5 of SNiP 3.01.04-87 and clause 3 of Appendix 1 to SNiP 3.05.05-84, commissioning "under load" with trial production of finished products, that is, comprehensive testing of equipment, is carried out before the object is accepted for operation, when the fixed asset has already been formed, but not put on the balance sheet of the enterprise. The taxpayer proved that after acceptance of the equipment of the workshop by the working commissions, he carried out a comprehensive testing of this equipment with the release of finished products and the costs of commissioning "under load" were not included in the construction estimate production complex(expenses for raw materials, semi-finished products, energy resources, salaries of production workers and workshop expenses). As a result, the court found it legitimate to classify the disputed costs as non-capital expenses. Not without interest is the Resolution of the Ninth Arbitration Court of Appeal dated May 27, 2009 N 09AP-7603/2009-AK<10>. The company reconstructed the unit and carried out its commissioning twice: first "without load" and then "under load". Based on the results of the commissioning work "without load", the working commission of the enterprise drew up an equipment acceptance certificate confirming that the reconstructed plant is in a condition suitable for use, ready for operation and production of products provided for by the project, in the amount corresponding to the standards for the development of design capacities. After the signing of the act, work began on a comprehensive testing of the installation "under load". The taxpayer included the costs of "idle" work in the cost of fixed assets, and he recognized the costs of performing work "under load" (more than 10 million rubles) at a time in accordance with paragraphs. 34 p. 1 art. 264 of the Tax Code of the Russian Federation. After checking the taxpayer, tax office came to the conclusion about the unlawful attribution of the costs of commissioning "under load" to other expenses of the reporting period, accrued additional income tax and penalties. The tax authorities proceeded from the fact that the initial cost of the fixed assets object is formed at the time of its commissioning, and not at the time of the signing by the working commission of the equipment acceptance certificate, therefore, all expenses incurred before the object was put into operation should form its cost. But the court supported the taxpayer, citing the following arguments:

  • in this case, the moment when the equipment is brought to a condition in which it is suitable for use is the date of acceptance of the equipment and signing of the relevant act. So, within the meaning of paragraph 1 of Art. 257 of the Tax Code of the Russian Federation, upon completion of commissioning "without load", the initial cost of the OS object was formed, that is, commissioning "under load" was carried out on a plant ready for operation after the formation of its initial cost;
  • complex technological equipment of the taxpayer could not be put into operation, bypassing the stage of commissioning (including "under load"), which preceded the signing of the act on putting the facility into operation;
  • commissioning ended with the release of finished products;
  • the cost of commissioning work "under load" was not included in design and estimate documentation for the reconstruction of the installation, but were approved by a separate estimate and, in terms of their content, were not of a capital nature.
<8>Approved by the Decree of the State Statistics Committee of Russia dated January 21, 2003 N 7.
<9>SNiP 3.01.04-87 "Acceptance for operation of completed construction facilities. Basic provisions", approved. Decree of the Gosstroy of the USSR of 04/21/1987 N 84.
<10>Left unchanged by the Decree of the FAS MO dated September 1, 2009 N KA-A40 / 8619-09.

In Decision No. А40-133100/10-76-783 dated April 15, 2011 Court of Arbitration Moscow sided with the inspectors. The Company carried out the capital construction of a single complex - a plant for the production of polypropylene, consisting of many facilities (from the equipment preparation building, the raw material purification plant, the receiving and dosing building, the production control building, the packaging and storage building, the warehouse for organometallic compounds, the laboratory and amenity building and others objects) combined into one whole and used only in common. In June 2007, the general contractor drew up acceptance certificates for the completed facility in the form N KS-11 for each facility of the plant. At the same time, the plant itself was accepted by the commission on the act of acceptance of the completed facility in form N KS-14 in September 2007. On the basis of the act in form N KS-14, the enterprise received permission from the municipal administration to put the plant into operation. All facilities included in a single complex (plant) were accepted as fixed assets under acts of form N OS-1 in December 2007. Before acceptance and commissioning of the plant, under act of form N KS-14, the company carried out in respect of all plant facilities (equipment and installations) commissioning related to testing the operation of the complex "without load" and "under load". The taxpayer, having considered that the cost of commissioning works "under load" (more than 34 million rubles), carried out after the general contractor drew up acts in the form N KS-11 in relation to each object of a single complex, is not subject to inclusion in the formed initial cost of the plant and each of the incoming in it objects, recognized these costs lump sum on the basis of paragraphs. 34 p. 1 art. 264 of the Tax Code of the Russian Federation. In accounting, the company recorded the costs of the specified commissioning as part of deferred expenses (on account 97) and started writing them off after the plant was put into operation and the production of polypropylene began. The court pointed out the fallacy of this approach: the costs of commissioning of equipment and installations carried out before the commissioning of the plant (in September 2007) should form the initial cost of the fixed assets. From the moment the act was drawn up in the form N KS-14, the object capital construction is considered completed, the initial cost is formed, and before the act is drawn up, all work and costs directly related to the capital construction of the facility are included in the cost of construction in progress and subsequently form the initial cost of the facility. Performing commissioning works "under load" or "without load" before the acceptance of the capital construction facility for operation by the acceptance committee under act form N KS-14 is a mandatory stage of construction, which is aimed at bringing the facility to a state in which it is suitable for use. The cost of such works is subject to inclusion in the formed initial cost of the object. A plant for the production of polypropylene is a single and indivisible industrial facility, consisting of many separate facilities (workshops, machinery and equipment, assemblies, installations, etc.), which is taken into account and put into commercial operation exclusively as a single facility - a plant. Each of the facilities included in the plant, for which in June 2007 acts were drawn up in the form N KS-11, by itself cannot perform a production function and be properly operated (produce products), therefore, the plant as a single complex was put into operation in September 2007 under act form N KS-14 as part of all facilities, including those in respect of which disputable commissioning work was carried out. Acts in the form N KS-11 cannot be the basis for the formation of the initial cost and the commissioning of each facility of the plant. The cost of the facilities was finally formed only in December 2007 after obtaining permission to put the plant into operation and drawing up acts in the form N OS-1 for each of the facilities included in the complex.

Example. The enterprise puts into operation a unit worth 590,000 rubles, including VAT - 90,000 rubles. Installation of equipment and all commissioning works are carried out by a specialized contractor. Estimated cost installation of the unit amounted to 354,000 rubles, including VAT - 54,000 rubles, the cost of commissioning work "idle" - 35,400 rubles, including VAT - 5400 rubles. The cost of commissioning during the period of complex testing of the unit "under load" is 11,800 rubles, including VAT - 1,800 rubles, the cost of fuel and electricity used during such work is 10,500 rubles. For the purposes of accounting and taxation of profits, the term beneficial use unit is installed in accordance with the Classification of property, plant and equipment included in cushioning groups <11>equal to eight years, depreciation is charged on a straight-line basis.

<11>Approved by Decree of the Government of the Russian Federation of 01.01.2002 N 1.

The accountant of the enterprise will make entries:

Contents of operationDebitCreditSum,
rub.
Accepted for accounting equipment requiring
mounting
07 60 500 000
Reflected the amount of VAT on the unit 19 60 90 000
Presented for VAT deduction on the unit 68 19 90 000
Reflected the transfer of the unit to the installation 08 07 500 000
Completed assembly work 08 60 300 000
Reflected the amount of VAT on installation work 19 60 54 000
Accepted for VAT deduction 68 19 54 000
Commissioning work "idle" accepted 08 60 30 000

working "idle"
19 60 5 400
Accepted for VAT deduction 68 19 5 400
Commissioning work accepted
"under load"
97 60 10 000

obligations
(10,000 RUB x 20%)<*>
68 77 2 000
Reflected the amount of VAT on commissioning
working under load
19 60 1 800
Accepted for VAT deduction 68 19 1 800
Reflected the cost of fuel and electricity
for commissioning "under load"
97 10, 60 10 500
Reflected the amount of deferred tax
obligations
(10,500 rubles x 20%)
68 77 2 100
On the date the unit was put into operation
The unit is reflected in fixed assets
(500,000 + 300,000 + 30,000) rub.
01 08 830 000
Monthly for a year from the date of putting the unit into operation
Recognized as part of the cost of conducting
commissioning
((10,000 + 10,500) rubles / 12 months)<**>
20 97 1 708
Written off part of deferred tax
obligations
(1708 rubles x 20%)
77 68 342
Monthly starting from the month following the month when the unit was switched on
composition of fixed assets
Depreciation charged on the unit
(830,000 rubles / 8 years / 12 months)
20 02 8 646
<*>For the purposes of taxation of profits, the costs of commissioning "under load" are recognized at a time on the basis of paragraphs. 34 p. 1 art. 264 of the Tax Code of the Russian Federation. At the same time, the date of recognition in tax accounting of the costs of paying for such work in this case is the date of acceptance of the results of the work performed from the contractor and the presentation by it of documents that serve as the basis for making payments for the work performed (clause 3, clause 7, article 272 of the Tax Code of the Russian Federation) . The date of recognition of expenses for the purchase of fuel and electricity used in the performance of these works is the date of their transfer to production (clause 2, article 272 of the Tax Code of the Russian Federation). different accounting and tax accounting the cost of commissioning leads to the formation of a taxable temporary difference and the corresponding deferred tax liability (PBU 18/02 "Accounting for corporate income tax calculations").
<**>The Organization has decided to write off deferred expenses on a straight-line basis (on commissioning "under load") within one year from the date of commissioning of the equipment.

E.V. Sholomova

Journal Expert

"Industry:

Accounting

and taxation"

Commissioning is an important stage of construction before putting the facility into operation. In the process of carrying out the commissioning work, routine adjustment and testing of equipment to ensure its safe operation throughout its life.

Specialists of OOO "Neftegazinzhiniring" are experienced engineers in the field of adjustment of electrical equipment for various purposes. Thus, we carry out commissioning of the following facilities: boiler plants, heat points, heat power plants, oil and gas processing and separation plants, gas use and gas distribution facilities, autonomous gas supply, ventilation and heating systems, dosing devices for reagents, etc. Full list objects you can check by phone 8-800-333-95-62.

Commissioning and commissioning can be carried out both as part of complex works on the design and installation of facilities, and separately on equipment not of our production and installation.

Stages of commissioning

Commissioning is a set of measures that allows you to put the object into operation and without which it is impossible to check the coherence of all engineering systems after completion of construction and installation works.

The task of the NDP are a comprehensive check of the correctness of the installation work, detection of factory defects in electrical equipment, setting up the operation of equipment in the maximum load mode and changing the technical parameters of electrical equipment to design consumer values. In case of detection of deficiencies in the installation performed by a non-construction and installation department of Neftegazengineering LLC, our specialists will select the most suitable equipment and, if necessary, correct the regime settings.

Diagnostics and adjustment of equipment guarantee the Customer reliability and uninterrupted operation of devices subsequently.

Commissioning begins with the preparation of an estimate for commissioning and the development of a commissioning program, which contains the entire scope of work required at a particular construction site.

AT typical scope of work for commissioning includes the following types of work:

  • preparatory work on familiarization with the equipment, preparation of estimates for commissioning and their list, verification of compliance with the technical parameters of the equipment design requirements and values
  • trial run to check the operability and functionality of individual devices, equipment and block diagrams with their output to operational values
  • complex testing and testing of equipment to check the performance of electrical equipment at maximum loads, testing of equipment at idle and under simulated force majeure circumstances
  • regime adjustment and adjustment of the interaction of equipment and all engineering systems of the facility with the launch of a permanent technological process, checking various operating modes