The Ministry of Finance clarified an important nuance for VAT when purchasing services from foreigners through an intermediary. Who is obligated to pay the tax if the payment was not made by the buyer himself? Read the explanation that is critical for your tax security.
Key Changes
The Russian Ministry of Finance has issued an official letter (dated 05.05.2025 N 03-07-08/44734) explaining the status of a VAT tax agent in a specific situation. We are talking about cases when a Russian company buys services from a foreign company, and the Russian Federation is recognized as the place of sale of these services, but the payment in favor of the foreigner is made not by the Russian company itself, but by a payment intermediary.
According to the Ministry of Finance's position, the Russian company purchasing services is recognized as the VAT tax agent in full, regardless of the fact that the actual payment to the foreign supplier was made by an intermediary. This means the Russian entity is obligated to:
1. Calculate VAT on the amount paid to the foreign service provider (through an intermediary).
2. Pay the calculated VAT to the Russian federal budget.
Recommendations for Businesses
Russian companies purchasing services from foreign contractors (with place of implementation in Russia) while using payment intermediaries must urgently verify their transactions for compliance with the Ministry of Finance's new position. It is critical to confirm proper fulfillment of VAT agent obligations for calculation and payment – even when using intermediary payment schemes. Failure to comply may result in tax reassessments, penalties, and fines.
How Acsour Can Help
The complex nuances of a tax agency, especially when interacting with foreign counterparties and intermediaries, require expert assessment. Acsour's professional team is ready to promptly audit your current transactions related to the purchase of services from non-residents and assist in the correct calculation and payment of VAT as a tax agent.