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The Russian Ministry of Finance has issued clarifications that are important for all companies to consider when preparing their tax returns. In Letter No. 03-03-06/1/117495 dated December 3, 2025, the authority reminded that a special procedure for correcting previous years' income tax errors has been in effect since January 1, 2026.
The Core Issue
If a company overstated its tax base in previous periods and now wishes to reduce it (for example, by discovering unaccounted expenses), but the income tax rate has increased in the current year 2026 — such errors cannot be corrected in the current period.
The Ministry of Finance explains: reducing the base for a period when the rate was lower by using a period with a higher rate leads to a distortion of tax obligations. Therefore, reflecting expenses from previous years in 2026 is not permissible.
The Ministry of Finance explains: reducing the base for a period when the rate was lower by using a period with a higher rate leads to a distortion of tax obligations. Therefore, reflecting expenses from previous years in 2026 is not permissible.
What This Means for Businesses
Companies that planned to account for previously unrecognized expenses in 2026 to lower their current tax base will face refusal from tax authorities. This approach is officially established and applies from January 1, 2026.
How to Handle New Contracts
If new contracts are concluded in 2026, the income and expenses from them are recognized in the usual manner — in the period to which they relate. The restriction applies only to correcting errors from previous years.
What Companies Should Do
- Review whether you have included adjustments for previous years' expenses in your 2026 budget.
- Understand that such expenses must be reflected through amended declarations for the periods to which they relate, with payment of penalties (if tax was underpaid).
- Consult with specialists to avoid mistakes and disputes with tax authorities.
Acsour experts are ready to:
Contact us — we will help you navigate complex situations and avoid tax risks.
- analyze your tax base and identify errors from previous years;
- prepare amended declarations for the relevant periods.
Contact us — we will help you navigate complex situations and avoid tax risks.
