On 23 July, the State Duma passed at third reading another major law as part of the ongoing tax reform (the “Law”). The proposed amendments are systemic in nature and provide for changes to 29 chapters of the Tax Code of the Russian Federation (the “Tax Code”). This overview outlines the amendments affecting the main categories of taxpayers.

1. The Government’s authority to issue regulatory legal acts in the area of taxation has been extended until 2028.
2. Documents sent to a taxpayer via telecommunication channels will be deemed received on the sixth day from the date of dispatch.
3. The accrual of late payment interest for organisations at a preferential rate has been extended until the end of 2024.
4. An overpayment offset against a specific tax and/or a positive balance in the Unified Tax Account will exempt the taxpayer from liability under paragraph 4 of Article 122 of the Tax Code.
5. Thresholds for transition to tax monitoring have been reduced by 20%.
6. Liability has been abolished for failure to provide documents confirming the profits of a controlled foreign company (CFC) in respect of sanctioned taxpayers.

A taxpayer will not be held liable for failure to provide documents confirming the amount of profit (loss) of a CFC if both of the following conditions are met:

1. sanctions are in effect against the taxpayer as the controlling person, consisting of a ban or restriction on the provision of such documents; and
2. the CFC is located in an “unfriendly” country.

Article 126 of the Tax Code is supplemented with a new paragraph 5 to this effect.

This relief will apply to documents confirming the profit (loss) of a CFC for the 2022–2024 financial years. The amendment is linked to difficulties in obtaining CFC financial documents due to sanctions.

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