Important Amendments to the Russian Tax Code Effective from 2026
The law introducing changes to the Russian Tax Code has been adopted. The amendments we reported earlier will take effect in January 2026.
We would also like to draw your attention to the following updates:
- During a field tax audit, the authorities may now review not only the three calendar years preceding the year in which the audit decision was issued, but also tax periods within the current year that were completed before the decision was made (Clause 4, Article 89 of the Tax Code);
- Even if multiple mitigating circumstances are present, tax penalties may not be reduced by more than tenfold (Clause 3, Article 114 of the Tax Code);
- The exemption for active holding or sub-holding CFCs from Russian taxation will be available only if the CFC is registered in a jurisdiction where the corporate profit tax rate is at least 15% (Clause 7, Article 25.13.1 of the Tax Code).
We continue to monitor developments and will keep you updated.
