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If your business is part of an international holding company or you are planning to enter foreign markets, it is important to understand: starting in 2026, the tax burden is changing not only for owners of Controlled Foreign Companies (CFCs) but also for participants in Multinational Groups (MNGs).
What Has Changed for MNG Participants
On January 1, 2026, amendments to the Tax Code (Federal Law No. 425-FZ) came into effect, requiring Russian participants of MNGs to pay profit tax at a minimum effective rate of 15%.
The new rules apply to companies that simultaneously meet three criteria:
The new rules apply to companies that simultaneously meet three criteria:
- the parent company of the group is located abroad and is a resident of a country that has implemented Pillar II rules;
- the group's consolidated revenue for two of the last four years exceeds €750 million;
- the effective tax rate of the Russian participant (taking into account all benefits) falls below 15%.
What Are the Risks and How Does This Relate to CFCs
Previously, companies could legally lower their effective rate by using preferential regimes or registering in low-tax jurisdictions. Now, if the rate falls below 15%, the Russian participant of an MNG is obliged to pay additional tax up to this level (5% to the federal budget, 10% to the regional budget).
For owners of CFCs that are part of large international groups, this creates an additional layer of complexity. It is now necessary to assess the consolidated effective rate of the entire group to avoid unexpected additional charges.
For owners of CFCs that are part of large international groups, this creates an additional layer of complexity. It is now necessary to assess the consolidated effective rate of the entire group to avoid unexpected additional charges.
The new rules are complex to calculate and require a review of intra-group structures and applicable benefits. Stabilization clauses for investment projects do not apply to the new rules. This means that even companies with previously agreed preferences may face additional charges.
The 2026 changes affect multiple contours of the tax system: both the rules for CFC owners and the new regime for MNG participants. Navigating this cascade of new obligations independently, without missing details or incurring fines, is extremely challenging.
Don't let legislative changes catch you off guard. Understand the new rules together with Acsour's experts.
The 2026 changes affect multiple contours of the tax system: both the rules for CFC owners and the new regime for MNG participants. Navigating this cascade of new obligations independently, without missing details or incurring fines, is extremely challenging.
Don't let legislative changes catch you off guard. Understand the new rules together with Acsour's experts.
