Dear colleagues,

This is a reminder that the deadline for submitting Notice of Participation in an International Group of Companies (hereinafter, the “IGC”) is August 31, 2025, for groups whose financial year coincides with the calendar year.

Filing the notice is an obligation for Russian organizations and foreign companies that recognize themselves as tax residents of Russia, which are part of an IGC and meet the criteria defined in article 105/16-1 of the RF Tax Code.

Below, we detail the key requirements, deadlines, and content of this notice.

1. The notice must be submitted by all IGC participants that are taxpayers in Russia, except for foreign organizations that only receive income specified in article 309 of the RF Tax Code (e.g., dividends, interest on debt obligations, etc.).

2. Exemption from the obligation

Exemption from the obligation to file the notice is provided in the following cases:

 If the IGC’s parent company or the appointed participant (which are Russian entities or foreign companies that have recognized themselves as tax residents of the Russian Federation) has already filed a notice containing information about all group participants.

 If the notice has been filed by another IGC participant (a Russian entity or a foreign entity that has voluntarily recognized itself as a tax resident of the RF), which has been assigned this obligation by the parent company or a non-resident appointed participant.

3. Filing deadline

The notice must be submitted electronically no later than eight months from the end of the reporting period of the IGC’s parent company (article 105.16-2 of the RF Tax Code). For example, if the reporting period ends on December 31, the filing deadline is August 31 of the following year.

4. Content of the notice

The notice must include the following information as of the end of the reporting period:

 Name, OGRN (Primary State Registration Number), INN (Tax Identification Number), KPP (Tax Registration Reason Code) of each IGC participant.

 Participant status (whether the filer is the parent company or the appointed participant).

 Details of the parent company: name, country of tax residency, registration and tax codes, address.

 Details of the appointed participant (if applicable): similar to the data required for the parent company.

 Grounds for submitting the notice on behalf of all IGC participants.

 End date of the reporting period.

5. Notice format

Notices must be submitted to the tax authorities electronically in XML format, in accordance with the current form established by Order No. ММВ-7-17/124@ of the Federal Tax Service of Russia dated March 6, 2018 (as amended on July 16, 2020) “On Approval of the Format of the Notice of Participation in an International Group of Companies, the Procedure for its Completion and Submission in Electronic Form“.

6. Correcting errors in the notice

If errors or incomplete information are discovered, the taxpayer has the right to submit an amended notice. If this is done before the tax service discovers the inaccuracy, the participant is exempt from liability under article 129.9 of the RF Tax Code.

7. Liability for failure to file the notice

Failure to submit the notice by the deadline or submission of inaccurate information entails a fine of 500,000 rubles for each violation. 

Practical recommendations:

  Determine if your group qualifies as an IGC. To do this, check if the group meets the criteria of article 105.16-1 of the RF Tax Code: whether consolidated financial statements are prepared, whether the group’s consolidated revenue for the financial year preceding the reporting year exceeds the threshold established in the country of tax residency of the group’s parent company, and whether the group includes at least one tax resident and one non-resident of the RF;

  Monitor the deadlines closely; late filing leads to fines;

  Use the correct format; the notice must be submitted only electronically in the format approved by the Federal Tax Service of Russia.

Conclusion

Submitting a notice of participation in an IGC is an important responsibility of members of international groups. Compliance with the deadlines and requirements for the content of the notice will help to avoid fines and claims from tax authorities.

Dear colleagues,

In 2025, tax monitoring continues to gain popularity: approximately 740 companies from more than 20 industries already use tax monitoring, another 143 companies plan to join the project and a total of more than 13,000 companies comply with the program criteria (according to the portal https://налоговыймониторинг.рф/).

Recently, we have noticed growing interest to this topic in the business community and in this review we have compiled answers to the most frequently asked questions about the procedure and conditions for applying the tax monitoring regime.

Tax monitoring is a special form of tax control, a method of extended information exchange, whereby an organization provides the tax authority with real time access to its accounting and tax records.

What are the advantages of tax monitoring?

• this type of tax control allows you to forget about traditional audits by the Federal Tax Service.
• no penalties or fines if you follow the reasoned opinion.
• you can find out about existing errors and discrepancies identified by the Federal Tax Service in real time.

Methods of information exchange:

• providing access to the organization’s information systems;
• by telecommunication channels through an electronic document management operator (until 01.01.2026, the Article 6 of the Federal Law No. 389-FZ of 31.07.2023);
• providing access to an analytical datamart.

An organization is eligible to apply tax monitoring if it complies with all of the following criteria (clause 3 of the Article 105.26 of the Tax Code):

• the total amount of taxes for the previous year was at least RUB 80 million (VAT, excise taxes, personal income tax, income tax, mineral extraction tax, insurance contributions are added up, except for VAT and excise taxes, which are paid when goods are moved across the customs border of the EAEU);
• income according to accounting (financial statements) for the previous year is at least RUB 800 million;
• the book value of assets as of 31 December of the previous year is at least RUB 800 million.

Important: compliance with one or two conditions does not entitle a business entity to apply tax monitoring. All three conditions are to be fulfilled.

There are exceptions to every rule, so compliance with the above conditions is not required for organizations specified in the clause 3.1 of the Article 105.26 of the Tax Code of the Russian Federation:

• residents of advanced development territories (ADTs),
• participants in industrial clusters,
• residents of special economic zones,
• former members of consolidated groups of taxpayers,
• state and municipal institutions, lottery operators.

It is also important to note that on April 29, 2025 the Ministry of Finance published draft amendments to the Tax Code (02/04/01-25/00154001), which include measures to improve tax monitoring.

The Ministry of Finance experts have proposed to weaken the requirements: in order to switch to tax monitoring, it will be necessary to comply with at least one of the criteria, for example, in terms of asset value, income or the amount of taxes paid.

The switch to tax monitoring is voluntary. If your company complies with all of the above criteria, in order to participate you are to submit an application not later than September 1 of the year (clause 1 of the Article 105.27 of the Tax Code of the Russian Federation) preceding the year of introduction of monitoring, including:

• regulations for information exchange (Appendix No. 7, the Order of the Federal Tax Service of Russia dated 11 May 2021 No. ED-7-23/476),
• information of the related parties — organizations and individuals who directly or indirectly participate in the organization and whose share of participation exceeds 25%,
• tax accounting policy for the current year,
• documents regulating the organization’s internal control system (ICS) (Appendix No. 13, the Order of the Federal Tax Service of Russia dated 11 May 2021 No. ED-7-23/476).

Until November 1 inspectors review the materials received and decide whether to perform tax monitoring or to refuse it, indicating the reasons for the refusal. Possible reasons for refusal are specified in the clause 5 of the Article 105.27 of the Tax Code of the Russian Federation, in particular:

• non-provision of documents or submission of incomplete documents by the organization;
• non-compliance by the organization with the monetary criteria (the Article 105.26 of the Tax Code of the Russian Federation);
• non-compliance of the information exchange regulations with the established form and requirements (Appendix No. 7, Order of the Federal Tax Service of Russia dated 11 May 2021 No. ED-7-23/476);
• non-compliance of the internal control system used by the organization with the established requirements for the internal control system (Appendix No. 13, Order of the Federal Tax Service of Russia dated 11 May 2021 No. ED-7-23/476).

In conclusion we should note, that in tax monitoring interaction takes place in real time and remotely instead of traditional audits. The company itself provides the tax authority with access to its accounting data.

This simplifies interaction with the Federal Tax Service, minimizes the risks of fines, penalties and additional charges. In addition, the company receives public recognition as a conscientious taxpayer and access to qualified support in complex tax issues. At the same time the company is obliged to be fully prepared to perform its activities openly and transparently and to comply with all reasonable opinions of the inspectors.

In the following reviews we plan to focus in more detail on various aspects of tax monitoring.

We will be glad to answer any questions you may have.

Dear colleagues,

we would like to inform you of the planned changes in the tax accounting which are expected in the nearest time.

As a general rule, according to the Article 54 of the Tax Code of the Russian Federation, if in the current tax period expenses relating to past periods are identified, they can be recognized in the current period.

However, according to the position of the Ministry of Finance, reflected in the Letter dated 15.05.2025 № 03-03-06/1/47786, the expenses of previous years cannot be recognized in the calculation of income tax for the current period if in the previous period the tax rate was lower as this will lead to an artificial understatement of current tax liabilities. Where errors (misstatements) in the calculation of the tax base relating to previous tax (accounting) periods are identified in the current tax (accounting) period, the tax base and the amount of tax should be recalculated for the period in which these errors (misstatements) were made.

The position of the Ministry of Finance is also confirmed by the latest bill 02/04/01-25/00154001, which amends the Article 54 of the Tax Code of the Russian Federation. The bill completes the Article 54 of the Tax Code with a provision prohibiting the recognition of expenses of previous periods in the current period if the tax rate of the current period is higher than the rate applicable in the period to which the errors relate.

With great probability the bill will be adopted in the nearest time, in such case the approach described by the Ministry of Finance will be established at the level of the Tax Code of the Russian Federation.

The planned date of coming into force of the amendments to Article 54 of the Tax Code of the Russian Federation is 1 January 2026. At the moment, when the amendments have not yet come into force, we recommend to follow the approach set out in the letter of the Ministry of Finance of Russia and include all expenses relating to periods earlier than 01.01.2025 in the adjusted declaration, rather than recognize them in the current period.

We will be glad to answer questions arising from the specified changes.

Exclusively for the Russian Business Guide magazine, Daria Pogodina, Managing Director of swilar presented a review article “CHANGES IN 2024: Double Taxation Agreements (DTAs), Transfer Pricing, Offshoring and other news” providing detailed step-by-step analysis of the changes and their consequences.

You can read the article online in Russian or English, or download two-language article in pdf-format by clicking the “Download ru” button below the message.