The Federal Tax Service has updated the list of#nbsp;foreign states and territories that do#nbsp;not provide for the exchange of#nbsp;tax information with the Russian Federation.
The specified list was approved by#nbsp;Order of#nbsp;the Federal Tax Service dated December 1, 2023 No. ED-7−17/914 and supplemented by#nbsp;the following countries:
Germany;
Latvia;
Switzerland;
Ukraine.
United Kingdom of#nbsp;Great Britain and Northern Ireland;
USA;
Countries such as#nbsp;Antigua and Barbuda, Vanuatu, Ghana, Grenada, Maldives, Oman, Peru, as#nbsp;well as#nbsp;the territories of#nbsp;Curacao and the Cook Islands were excluded from the list.
Taking into account the changes, the number of#nbsp;countries in#nbsp;the list is#nbsp;88 (previously 89), and territories#nbsp;— 14 (previously 16).
The presence of#nbsp;a#nbsp;country on#nbsp;such a#nbsp;list entails tax consequences for Russian tax residents. Since in#nbsp;the absence of#nbsp;a#nbsp;country in#nbsp;such a#nbsp;list, the profit of#nbsp;the same controlled foreign company is#nbsp;exempt from taxation if#nbsp;its permanent location is#nbsp;a#nbsp;state with which Russia has an#nbsp;international tax treaty.
The Federal Tax Service also issued Order No. ED-7−17/915 dated December 1, 2023, which approved a#nbsp;list of#nbsp;states that allow systematic non-fulfillment of#nbsp;obligations for the automatic exchange of#nbsp;country reports.
As#nbsp;a#nbsp;general rule, international groups of#nbsp;companiesare required to#nbsp;submit an#nbsp;annual country report for the previous financial year. International groups of#nbsp;companies' participants may not submit this report if#nbsp;the parent company of#nbsp;international groups of#nbsp;companies reports in#nbsp;one of#nbsp;the countries with which the Federal Tax Service has established an#nbsp;automatic exchange of#nbsp;such reports. For these purposes, the regulatory authorities maintained an#nbsp;up-to-date list of#nbsp;countries with which country reports were automatically exchanged.
However, since the publication of#nbsp;the new Order, the automatic exchange of#nbsp;country reports will continue, but at#nbsp;the same time, systematic non-fulfillment of#nbsp;obligations under such an#nbsp;exchange is#nbsp;allowed. The specified list includes 21 States, namely:
Australia
Austria
Belgium
Cyprus
Denmark
Finland
France
Germany
Greece
Ireland
Italy
Japan
Luxembourg
Netherlands
Norway
Poland
Portugal
Romania
Slovenia
Spain
Sweden
At#nbsp;the same time, the Russian participants of#nbsp;the international groups of#nbsp;companies, whose parent companies are located in#nbsp;the states included in#nbsp;the new Order, have additional obligations to#nbsp;the Federal Tax Service of#nbsp;Russia, namely, the submission of#nbsp;a#nbsp;country report at#nbsp;the request of#nbsp;the Federal Tax Service.
To#nbsp;fulfill such a#nbsp;requirement, taxpayers will need to#nbsp;prepare and submit a#nbsp;Country Report in#nbsp;a#nbsp;timely manner (no#nbsp;later than three months from the date of#nbsp;receipt of#nbsp;the request) in#nbsp;electronic format in#nbsp;accordance with the requirements for the preparation of#nbsp;an#nbsp;XML schema of#nbsp;a#nbsp;country report established by#nbsp;Order of#nbsp;the Federal Tax Service of#nbsp;Russia dated March 6, 2018 No. MMV-7−17/123.
For questions about the preparation and provision of#nbsp;documentation of#nbsp;the international groups of#nbsp;companies, please contact Acsour experts.