Lithuania-Poland-Russia ENPI Cross-border Cooperation Programme 2007-2013
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Lithuania-Poland-Russia ENPI Cross-border Cooperation Programme 2007-2013 BW

Budget and finance

Q: Can costs of personal involved in the project implementation be regarded as the beneficiary's own contribution?
Yes, provided it is not in kind contribution.

Q: Is it possible to make a budget amendment (e.g. shifting the budget lines) at the level of project implementation?
Yes, there is such possibility.

Q: What exchange rate should be used in project budget?
Budget must be calculated in EURO. Monthly exchange rate is available at:  
It is suggested to use the exchange rate of June 2010. But it is possible to use rate of other month, if it is more convenient for Applicants.

Q: What type of costs can be included in overheads line?
Indirect administrative costs (overheads) are related to office running for the purposes of the action. Indirect costs are the costs which are not directly related to activities of the action, but needed for the smooth administration of the action. The flat rate of the overhead costs is calculated as a ratio and expressed as a percentage and shall not exceed 7% of total eligible direct project costs. This means that in case the total accepted cost of your project is lower than the cost indicated in the budget, the amount accepted under this budget heading will be reduced accordingly.The allocation of the organisation's eligible administration costs to the project could be done on the basis of the following keys (depending on which key best reflects the type of cost): the ratio "number of people working for the project / number of people working in the organisation or department" or the ratio "number of hours worked on the project / number of hours worked in total in the organisation or department" or the ratio "surface used by the personnel working for the project/surface of the organisation or department".

Q: Is there a minimum threshold for co-financing by each action partner?
No, there is no minimum threshold set for the co-financing by each partner. Not less than 10% of the total eligible costs of the action are the applicant's and/or partner(s) own contribution to the action and must be financed from their resources or from sources other than the European Community budget or the European Development Fund. Applicant and partners must contribute to financing of the action. The amounts of such contribution are to be decided between the applicant and its partners and their indicative distribution indicated in the Application Form and Partnership statement.

Q: Do all partners must contribute to financing of the project?
No, there might be situations - when it will be justified when one or more partners will not financially contribute (for example they appearance in the project is needed because of their exceptional know-how,etc.).

Q: Who can get per diems?
Per-diems can be paid to the staff assigned to the Action, but budget line 5.7 Costs of conference/seminars can cover accommodation and meals of events participants.

Q: Can the co-financing of 10% be collected from the action participants (e.g. participation fee in trainings) or tender winner?
No. The co-financing must be provided by the organisations indicated in the Grant Application Form, (partners and applicants). Such co-financing can be from their own resources or from sources other than European Community budget or European Development Fund (see guidelines for Grant Applicants, Section 1.3).

Q: Shall the Beneficiary transfer the grant amounts to each partner according to the implemented activities and the partners shall pay the invoices themselves, or is it possible that the Beneficiary shall directly pay the eligible expenditure according to the planed budget?
A: Both options are possible and it is up to the internal agreement (most probably included into the Partnership Agreement) concluded by partners. The Beneficiary shall receive the grant and it undertakes to carry out the Action under its own responsibility. Thus the Beneficiary should select the system that is acceptable for the partners to implement the action and should ensure that the costs incurred and reported are eligible.

Q: Does the Program envisage any partial eligibility of VAT? (Our institution can partially reimburse VAT).
A: VAT, i.e., Value Added Tax is considered as ineligible unless the beneficiary and/or partners cannot reclaim it, and the applicable regulations do not forbid coverage of taxes (see Guidelines for Applicants 2.1.4).

Q: Is it possible to get some pre-payment from programme for Russian, Lithuanian or Polish partners, in case of approved application? Or all payments during project implementation should be payed by project partners own budget and only after project report 90 % of payments will be recovered by programme?
Yes, it's possible to get pre-payment in accourdance with the schemes: first pre-payment 30%, second instalement - 40%, final payment 30%; or first pre-payment 30%, second and third - 30 %, final payment 10% (see Guidelines for Applicants 2.6).

Q: Social security, tax and other staff costs - are these elegible costs to be foreseen in the project budget for Poland, Lithuania and Russia?
A: Calculation of salary should follow national legislation, thus social security taxes and incom taxes are eligible.

Q: Please, provide explanation if copies of the profit and loss account and the balance sheet or other relevant fiscal documents for the last 3 years (if applicable), showing the financial anding of the applicant and every partner with financial contribution to the project (Annex A3) shall be provided for every project, or it depends on the sum?
:Yes, Annex A3 shall be provided with every project.

Q: What are the requirements and mechanisms concerning financial liabilities and guaranties of leading partner towards JMA/JTS and project partners towards leading partner?
: Requirements regarding Lead Partner responsibilities to JMA/JTS are provided in Annex D of the Guidelines. Assumptions to the Partnership Agreement (agreement between Partners) are provided in Annex F of the Guidelines.

Q: What is in the situation when infrastructure project generates some income. Precisely, it`s a project concernig conversation of a building into a youth hostel. On this area youth hostel is still in action, they have a few small wooden cottage and social building mentioned above. It is naturally that they take fees for stay and of course they  generates some income. My question is: Do we have to considered public aid regulations or calculate finacial gap according to EU Treaty and EU and Nationals Public Aid Regulations ? Total amount of the project is no more then 1 mln PLN.
: In accordance with Guidlines section 2.2.4.For the purpose of equal treatment of applicants, the JTS/JMA cannot give any prior opinion on the eligibility of an applicant, a partner, an action or specific activities. In accordance with Guidlines section 2.1.3. "actions that have the purpose or effect of producing a profit for the Applicant or other project partners" are not eligible.

Q: Can we sell books published during the project implementation period?
All the projects within this Programme must be of non-profit profile, thus no grant should have the purpose or effect of producing a profit for the Applicant and partners. In case the implementation of the project activities shall generate any kind of revenue (e.g. participation fees, selling the publications, fees related with connecting to infrastructure, etc) please indicate the respective values in Annex B (Budget), worksheet 3 (Expected sources of funding) - see instructions on filling in Grant Application Form. A grant for an Action must be limited to the amount required to balance income and expenditure for the Action (Annex II, General Coditions, Article 17.3).

Q: In which budget line can we put financial sources for maintainaning the building where trainings, courses, meetings of partnership and practices for the target group in the frame of project realisation will be organised?
A: The costs for maintenance of the building mentioned in the question can fall under budget lines either  4 or 5, or 11 - it all depends on nuances of the Project which we cannot give our prior opinion on (Guidelines for Grant Applicant, section 2.2.4).


The Lithuania – Poland – Russia Programme
is co-financed with the funds from the European Union
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