What should you do if the auditor’s report on the CFC financial statements is not ready by April 30?
By April 30, individuals must submit a notification on controlled foreign companies (CFCs) for the 2025 tax period, together with the companies’ financial statements for the 2024 financial year. In certain cases, the CFC financial statements must be accompanied by an auditor’s report.
This requirement applies where the CFC is registered in a jurisdiction:
— that does not have a double tax treaty with Russia; or
— that is included in the list of jurisdictions that do not ensure exchange of tax information with Russia.
If the auditor’s report is not ready at the time of filing the notification, the following approach may be used. When submitting the CFC notification, the taxpayer may indicate the latest possible date for the preparation of the auditor’s report, for example, July 15, 2026. In this case, the taxpayer will have an additional one-month period from that date to submit the auditor’s report, i.e., until August 15, 2026.
This mechanism is provided by Clause 6 of Article 25.15 of the Russian Tax Code and allows taxpayers to avoid a RUB 500,000 penalty for submitting financial statements without an auditor’s report.
Therefore, if the audit is not completed by April 30, it is important to correctly determine the date of the auditor’s report in the CFC notification and comply with the additional deadline for its submission.
