On April 18, 2025, a List of Presidential Instructions was published, which includes an instruction to develop a special procedure for the return of foreign companies[1] to Russia, and an instruction to maintain a list of foreign companies that have curtailed or discontinued operations in Russia after February 22, 2022[2].

It is anticipated that a special procedure will be established for the following transactions (operations) involving persons from so-called “unfriendly countries”:

1. Acquisition of real estate by persons from “unfriendly countries” for the purpose of owning, possessing, or using such real estate to conduct business activities in Russia;
2. Acquisition by persons from “unfriendly countries” of the rights to directly or indirectly dispose of shares (interests) in companies, or other rights that would enable them to determine the conditions of management of such companies and/or the conditions of their business activities.

What will happen to the previously granted buyback options?

Among other things, the Russian President has instructed to develop a special procedure for the sale of buyback options for Russian assets sold on non-market terms after February 22, 2022. The Russian government appears to be sending a message that the return of such assets will be scrutinized more closely by the Russian regulatory agencies and will probably require separate additional approval and compliance with some requirements that have yet to be developed.

However, it is a well-known fact that there is already a formal procedure for approving transactions (operations) involving real estate, shares (interests) in Russian companies with the participation of foreign “unfriendly” persons. Therefore, it is likely to be about the development of certain conditions for foreign companies to enter the Russian market.

We will be monitoring the situation closely and keep you informed as soon as there are any changes to the legislation.

Still have questions or want to discuss something? Send an email to Julia Talagaeva or Artem Eretenko.

 

[1] The term “foreign companies” means companies from so-called “unfriendly countries”, a list of which was approved by Directive No. 430-р of the Russian Government dated March 5, 2022

[2] http://www.kremlin.ru/acts/assignments/orders/76722 (in Russian)

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New rules on the use of SIM cards by foreign citizens start to apply in Russia from January 1, 2025. Foreign citizens are now required to undergo additional identification to keep their access to mobile communications and banking services. Those who will not confirm their mobile numbers by June 30, 2025 risk losing their communications, because mobile operators will stop servicing unregistered SIM cards.

Who are the new rules for?

The requirements apply to all foreign citizens using Russian SIM cards. This includes those who live in Russia and those who visit Russia from time to time. This innovation is especially important for those foreign citizens who use Russian SIM cards for their mobile banking applications, online banking systems, and other services that require SMS verification codes.

What do you need to do?

 To keep your mobile number, you must take the following steps **by June 30, 2025**:

1. Obtain a SNILS (Individual Insurance Account Number).
2. Create and confirm an account on the Russian Public Services Portal (Gosuslugi).
3. Register in the Unified Biometric System by submitting your biometric data (photo and voice).
4. Confirm your SIM card either at your mobile operator’s outlet or through the Gosuslugi

The same rules apply to new SIM cards purchased after January 1, 2025.

What happens if you don’t do it?

 If you do not complete this procedure on time, your mobile operator will suspend the service of your mobile number. As a result, you may lose access to your banking and other online services.

We will be pleased to advise you on the confirmation of your SIM card and on any migration matters that you may have.

Do you have any questions or would like to discuss something? Please send an email to Julia Talagaeva or Alexandra Yudina.

Sincerely,

Forte Tax & Law Team

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The Law On Limited Liability Companies allows for situations where a shareholder’s share may be transferred to the company for one reason or another, and the shareholder ceases to hold a share in the company. In such a case, the company must pay the shareholder the actual value of the shareholder’s share. For example, this situation arises in the following cases[1]:

• if a shareholder is permitted to withdraw from the company (as is expressly provided for in the company’s charter), and the shareholder has applied for withdraw;
• if a shareholder requires the company to acquire the shareholder’s share, provided that the company’s charter prohibits a shareholder from withdrawing from the company and from selling his share to a third party, and the other shareholders have refused to purchase the shareholder’s share;
• if the company’s charter provides that the heirs of a shareholder may not become shareholders of the company, or other shareholders’ consent is required to do so, and such consent has not been given; or
• if, at the request of creditors, the share, or a portion thereof, owned by a shareholder of the company becomes the subject of execution proceedings.

The actual value of the share corresponds to a portion of the value of the company’s net assets that is proportional to the size of the shareholder’s share. The value of the company’s net assets is calculated on the basis of the company’s financial statements. For this reason, the actual value of a share may differ from its market value. Often it may be lower.

There have been previously court disputes  in which the plaintiffs have attempted to bring the actual value of a share closer to its market value. The courts in a number of cases have argued that the market value of real estate, rather than its accounting residual value[2], should be used to calculate the value of the company’s net assets and the actual value of a share.

At the end of March 2025, a draft law was submitted to the Russian State Duma, according to which the actual value of a share is to be determined and paid at its market value, if the person, to whom the actual value of a share, or a portion thereof[3] is to be paid, so declares. An appraiser will be engaged to determine the market value of a share. At the same time, the draft law states that if the person, to whom the actual value is to be paid, requests that the market value of a share be paid, it will not be permitted to use any value, except the market value.

These changes could result in significant risks to joint ventures if a shareholder withdraws, as the market value of a share may be much higher than its actual value, which could create significant risks to the very existence of the company.

We recommend reviewing your company’s charter to determine whether it prohibits a shareholder from withdrawing from the company and making other changes to the charter that will protect your company’s activities if a shareholder decides to withdraw.

We will be happy to draft amendments to your company’s charter for you that will meet your needs and minimize the risks associated with the withdrawal of shareholders.

Do you have any questions or would like to discuss something? Please send an email to Anton Kabakov or Alexandra Yudina.

[1] Article 23 of Federal Law No. 14-FZ dated February 8, 1998 On Limited Liability Companies.

[2]Resolution No. 15787/04 of the Presidium of the Russian Supreme State Commercial Court dated June 7, 2005 in Case No. А53-15243/02-С4-11, Resolution No. 5261/05 of the Presidium of the Russian Supreme State Commercial Court dated September 6, 2005 in Case No. А50-10328/2004-Г25, Resolution No. 16191/11 of the Presidium of the Russian Supreme State Commercial Court dated April 17, 2012 in Case No. А40-18600/05-134-138, and Ruling No. ВАС-5228/13 of the Russian Supreme State Commercial Court dated May 6, 2013 in Case No. А54-329/2010.

[3] Draft Federal Law No. 876952-8 On the Introduction of Amendments to the Federal Law ‘On Limited Liability Companies’.

 

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Forte Tax & Law would like to remind you of the importance of holding an annual meeting of shareholders (members) of your company and of drawing up minutes of the meeting. This year, meetings are to be held in accordance with the updated rules, which requires more attention to avoid mistakes.

LLCs must hold an annual meeting by April 30, 2025, and JSCs must do so by June 30, 2025. Failure to hold a meeting or to meet the deadline could potentially result in substantial fines.

The mandatory matters to be decided at the annual meeting are:

• the approval of the balance sheet and the statement of financial performance;
• the approval of a company annual report.

Depending on the structure of your company’s management bodies and the provisions of the charter, the annual meeting must also adopt resolutions, in particular, on the formation of the board of directors and on any other matters, for example, on the distribution of dividends, approval of transactions, conduct of an audit, etc. The notice of the meeting must contain all matters proposed for discussion at the general meeting of shareholders (members), along with the relevant documents.

If your company’s charter (relevant for LLCs and non-public JSCs) has not been amended to allow annual meetings to be held fully in absentia, these meetings must be held in person—i.e., in the joint presence of shareholders (members) or in person/absentia (when some participants are present in person while others are in absentia). Where shareholders (members) are to be represented by proxies in a meeting, it is essential that these proxies must be issued with powers of attorney that can prove their authority. Powers of attorney issued in foreign countries must be apostilled or legalized and accompanied by a Russian translation.

In addition to the in-person format, an annual meeting can also be held remotely.

All the results of the meeting must be recorded in minutes signed as required by the charter. Please note that if the meeting elects an executive body, such a resolution must be notarized, irrespective of the provisions of the charter.

We would be pleased to assist you with holding meetings and drawing up all necessary documents as prescribed by the new rules.

If you have any questions or you would like to discuss something, please send an email to Julia Talagaeva or Alexandra Yudina.

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Letter No. 27-01-21/11349 of the Russian Ministry of Finance dated February 10, 2025 was recently published, which is another attempt to clarify the procedure for including dividends in the customs value of goods.

The Russian Ministry of Finance, like the Russian Supreme Court before it, points out that in a situation where goods are imported as part of transactions between members of the same group of companies, and the income (revenue) of a Russian buyer is primarily derived from the sale of imported goods, the decision to pay dividends is solely at the discretion of the foreign group of companies, which creates a risk of manipulation of the customs value.

If the customs authorities find that the payments described as dividends are such only in form, but in essence ensure that the seller, which is a member of the same group of companies with members of the company, receives part of the income (revenue) due to it from the sale of imported goods, such payments will be included in the customs value of the goods pursuant to Article 40(1)(3) of the EAEU Customs Code.

In this new letter, the Russian Ministry of Finance describes the circumstances that the declarant must confirm for the declared customs value of the imported goods to be recognized as valid. The Russian Ministry of Finance states that the declarant is required to confirm that the price actually paid or payable for the goods was formed in the ordinary course of trade—i.e., the goods were purchased under competitive market conditions. Simply put, the importer must show that any person can purchase the goods at the same price and under the same conditions as the importer that pays dividends, but without a shareholder relationship and without the payment of dividends. In practice, this can be quite difficult in a situation where the sale of goods is arranged through the importer’s own network of local subsidiary distributors.

What is interesting about the new clarifications is that in the letter the Russian Ministry of Finance takes the position that dividends should also be included in the customs value of goods:

• if the declarant fails to provide information on the exporter’s pricing methodology; or
• if there is no evidence of the market level of the price, including due to a limited number of buyers of such goods.

In practice, when the customs authorities check for the inclusion of dividends, they often (but not always) disregard the declarant’s arguments that the price of the imported goods corresponds to the market price level.

Therefore, the new clarifications of the Russian Ministry of Finance give hope that in the future, when conducting inspections, the customs authorities will take into account the fact that the price of the imported goods corresponds to the market level and, consequently, there is no manipulation of the price, no understatement of the customs value and no reasons for revising it.

Furthermore, it is the declarant that bears the burden of proving the market level of the price, the method of its formation, taking into account the usual market factors, the submission of transfer pricing documentation, and the calculation of such price elements as  the production cost, the markup that covers expenses and provides a market markup for a relevant product, etc. In this regard, it will be crucial to prepare a detailed response to the very first request from the customs authorities.

If you have any questions or you would like to discuss something, please send an email to Julia Talagaeva.

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On January 21 and 29, 2025, the Russian State Duma passed in the first reading draft laws clarifying the rules for exercising a preemptive right to purchase an interest in a limited liability company (the “Draft Laws”) .

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The Russian Constitutional Court heard a case[1] of an employee who had been dismissed from his principal place of work due to redundancy. The employer paid the employee a severance allowance, but refused to pay the employee’s average monthly earnings for the period of finding a new job [2]. The employer believed that the employee was a dual job holder and, therefore, such an employee was not entitled to a guarantee in the form of payment of his average monthly earnings. The courts sided with the employer in a dispute with the employee.

However, the Russian Constitutional Court ruled that such a reading of the law was inconsistent with the Constitution. Upon dismissal from the principal place of work, an employee loses part of the total labor income (which may be significant). This leads to the need to find a new job. Moreover, dismissal from the principal place of work does not transform a dual job employment contract into a principal one. Therefore, taking into account these factors, it is impossible to deprive dual job holders of guarantees in the form of payment of average monthly earnings for the period of finding a new job.

Thus, the Russian Constitutional Court held that the failure to pay average monthly earnings to a dual job holder upon dismissal from the principal place of work due to liquidation or downsizing/redundancy is contrary to the Constitution. This means that the employer is obligated to pay such an employee average monthly earnings for the period of finding a new job, even if the employee has another paid job with another employer.

What are the implications of this ruling for employers and employees?

First, until changes are made to applicable Russian laws, the employer will be obligated to follow the position of the Russian Constitutional Court. Second, an employee may apply to the employer asking for the payment of the employee’s average monthly earnings, if such earnings have not been paid. And the employer will be obligated to pay them. Third, there is a high risk that valid decisions on similar disputes between employees and employers will be overturned. These are decisions that contradict the position of the Russian Constitutional Court.

The Forte Tax & Law team will be pleased to advise you on labor law issues and the resolution of labor disputes.

If you have any questions or you would like to discuss something, please send an email to Julia Talagaeva or Ekaterina Beliaeva.

[1] Ruling No. 54-П of the Russian Constitutional Court dated November 22, 2024 In the case of the verification of the constitutionality of parts two and three of Article 318 of the Russian Labor Code in connection with the complaint filed by citizen V. V. Sergeev.

[2] Average monthly earnings can be paid for up to six months.

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On January 18, 2025, the Russian Ministry of Finance announced that a double tax treaty with the UAE had been initialed—i.e., the text of the double tax treaty with the UAE has been finalized.

Withholding tax on dividends, interest, and royalties under this treaty are proposed to be 10%. Moreover, according to Deputy Finance Minister Alexey Sazanov, who participated in the initialing, the treaty will have “sufficiently standard” terms. The parties plan to sign the treaty soon and will make every effort to ensure that it enters into force on January 1, 2026.

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From March 1 to April 30, 2025, members of limited liability companies must approve the annual results for 2024 at a general meeting, with participants required to attend in person or through authorized representatives. While remote voting for annual meetings has been allowed in recent years, this practice will be limited starting March 1, 2025. Instead, companies will be able to hold hybrid meetings, where both in-person and remote participation is allowed, provided the company’s charter or unanimous participant decision allows it. It is recommended to amend the charter in advance if necessary and ensure the company has an internal document outlining the procedure for remote voting.

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Starting from January 1, 2025, significant changes in tax legislation have come into effect in Russia, affecting both individuals and legal entities. A progressive personal income tax scale, an increase in corporate profit taxes, new deductions, changes in the taxation system for small and medium-sized businesses, as well as the introduction of a tourist tax—all of these factors will have a significant impact on financial planning and tax obligations. In this article, we’ll take a closer look at the key changes to the tax system that will take effect in 2025 and explain how they may impact taxpayers.

Personal income tax

Starting from 01.01.2025, the progressive personal income tax scale has been significantly expanded.

Instead of the two rates—13% and 15%—for the main types of income of Russian tax residents, five different rates are being introduced, each applied to the amount exceeding the threshold of the previous one (Article 224(1) of the Russian Tax Code):

• 13% on income up to RUB 2.4 million inclusive;
• 15% on income from RUB 2.4 million to RUB 5 million per year inclusive;
• 18% on income from RUB 5 million to RUB 20 million per year inclusive;
• 20% on income from RUB 20 million to RUB 50 million per year inclusive;
• 22% on income more than RUB 50 million per year (Article 210(2.1) of the Russian Tax Code).

For income in the form of remuneration paid to persons working in the Far North, and participants in the Special Military Operation, the current tax rates will remain: 13% on income up to RUB 5 million inclusive; 15% on income more than this amount (Articles 224(1.2), 210(6.1) and 210(6.2) of the Russian Tax Code).

Furthermore, for certain types of income of tax residents of Russia, such as income from the sale of property; insurance income; income from equity participation (dividends); income from transactions with securities, shares, and derivative financial instruments; certain types of financial benefits; income from REPO transactions and interest on deposits, the following rates have been established  (Article 210(6) of the Russian Tax Code):

• 13% on income up to RUB 2.4 million inclusive;
• 15% on income over that amount (Article 224(1.1) of the Russian Tax Code).

The tax rates on the income of certain tax non-residents of Russia have also been changed. Thus, the income of highly-qualified specialists, foreign citizens employed, ship crews, and refugees will be taxed according to the five main tax rates. These same rates will apply to the income of employees working remotely from abroad, as well as individuals providing online services from abroad using Russian domain names.

Starting from 01.01.2025, the amount of the standard tax deduction for the second and subsequent children has been increased

The tax deduction for the second child has been increased from RUB 1,400 to RUB 2,800. For the third and each subsequent child, it has been raised from 3,000 to 6,000 rubles. Additionally, the deduction for each disabled child has been increased from 6,000 to 12,000 rubles. The total income threshold at which the deduction ceases to apply has also been raised from 350,000 to 450,000 rubles. The deduction will be provided by the employer (as the tax agent) without requiring a formal request from the taxpayer-employee (Article 218(1)(4) of the Russian Tax Code).

A new standard tax deduction introduced from January 1, 2025

A tax deduction of 18,000 rubles per tax period will be granted to individuals who have passed the GTO (Ready for Labor and Defense) physical fitness standards and have confirmed their awarded distinction, provided they have also undergone a medical examination.

Changes in Personal Income Tax Calculation by Tax Agents

When calculating personal income tax, the tax agent considers the actual expenses incurred and documented by the individual taxpayer based on their application (Article 266(11) of the Russian Tax Code). The deadline for notifying the tax authorities about the inability to withhold PIT has been extended until January 31 of the year following the reporting tax period (Article 266(5) of the Russian Tax Code).

Additionally, the list of tax agents has been expanded. It now includes:

• Foreign organizations that pay income to taxpayers providing online services from abroad using Russian domain names (the requirement to tax such income also comes into effect on 01.01.2025).
• Russian organizations that provide technical capabilities for rendering such services (Article 266(1.1) of the Russian Tax Code).

Mining Income is Subject to Personal Income Tax

Income from Russian sources includes earnings in the form of digital currency obtained through cryptocurrency mining in Russia (Article 208(1)(9.3) of the Russian Tax Code).

Such income is recognized as in-kind income, and the value of the digital currency is determined based on its market quotation on the date the income is actually received (Article 211(1) of the Russian Tax Code).

At the same time, a tax deduction is provided for documented expenses related to cryptocurrency mining (Article 220(1)(5) of the Russian Tax Code).

Changes to Personal Income Tax exemptions

Starting from January 1, 2025, the exemption from personal income tax (PIT) on income from the sale of shares or stakes in the authorized capital, due to ownership for more than five years, will only apply to taxpayers who are tax residents of Russia (Article 217(17.2) of the Russian Tax Code). A limit of RUB 50 million has also been set for the amount of exemption. Furthermore, the method for calculating the tax-free severance pay (equivalent to three months’ salary) has been modified. It will now be calculated in the same manner as maternity benefits and monthly childcare allowances (Article 217(1) of the Russian Tax Code).

CFC fixed profits changed for 2025

For one CFC, fixed profits are set at RUB 27,990,000, for two CFCs, at RUB 52,718,000, for three CFCs, at RUB 75,445,300, four CFCs, at RUB 98,172,600, and five or more CFCs, at RUB 120,899,900 (Article 227.2(2) of the Russian Tax Code).

Corporate Income tax

Income tax rates will go up

Ef Starting from January 1, 2025, the general corporate income tax rate has been raised from 20% to 25% (Article 284(1) of the Russian Tax Code). The additional 5% will be allocated to the federal budget: instead of the previous 2%, 7% will now be directed to the federal budget (8% from 2025 to 2030).

The tax rate for IT companies has also increased by 5%, from 0% to 5%. The additional 5% will also be allocated to the federal budget. Furthermore, a limitation has been introduced – this rate will only apply until 2030. After 2030, IT companies will be required to apply the general rate of 25% (Article 284(1.15) of the Russian Tax Code). Additionally, a 5% increase has been introduced for Russian organizations engaged in the radio-electronics industry, raising the rate to 8%. This rate will only be applicable until 2027, and the tax will be allocated to the federal budget (Article 284(1.16) of the Russian Tax Code). Moreover, the tax rate on interest income from government and municipal securities, as well as mortgage-backed bonds, has been increased by 5% to 20% (Article 218(4)(1) of the Russian Tax Code).

Other Changes in Specific Corporate Income Tax Rates

For organizations included in the register of small technology companies, regional laws may establish a reduced corporate income tax rate for the portion allocated to regional budgets in the period from 2025 to 2030 (Articles 284(1.85) to 284(5) of the Russian Tax Code). The tax rate on income from hydrocarbon extraction at new offshore fields has been reduced from 50% to 40%. This rate applies from the 8th to the 12th tax period from the start date of extraction (Articles 284(1.4) of the Russian Tax Code Income from the development of subsurface resources, under certain conditions, is taxed at a 20% rate (Articles 284(1.17) to 284(1) of the Russian Tax Code). Income from oil transportation in the tax periods from 2025 to 2030 will be subject to a 40% tax rate (Articles 284(1.19) of the Russian Tax Code).

A federal investment deduction introduced

In addition to the existing regional investment tax deduction, a federal investment deduction has been introduced (Article 286.2 of the Russian Tax Code). Taxpayers can choose only one of these deductions.

The federal deduction allows companies to reduce their corporate income tax (or advance payments) allocated to the federal budget by covering specific expenses, including:

Acquisition, construction, manufacturing, and delivery of certain fixed assets, as well as bringing them to a usable condition.

Completion, retrofitting, reconstruction, modernization, or technical re-equipment of such fixed assets and/or intangible assets (IA).

This deduction is available to taxpayers whose primary business activity (as listed in the Unified State Register of Legal Entities, EGRUL) falls under one of the following categories:

• Mining
• Manufacturing industries
• Electricity, gas, and steam supply; air conditioning
• Hotel and food service activities
• Scientific research and development
• Telecommunications
• Information technology

A participant in the ERA Technopolis exempted from tax

An entity that has been granted the status of a participant in the ERA Technopolis is entitled to exemption from the duties of an income taxpayer for 10 years (Article 246.1-1 of the Russian Tax Code).

Increased Adjustment Coefficients

The adjustment coefficient applied to expenses related to acquiring the right to use software (SW) and databases has been increased from 1.5 to 2. Additionally, the scope of this coefficient has been expanded to include expenses for acquiring software-hardware systems, as well as for adapting and modifying software and databases (Article 264(1)(26) of the Russian Tax Code). In addition, the coefficient applied to R&D expenses has been increased from 1.5 to 2 (Article 262(1)(4) of the Russian Tax Code).

Extended Exchange Rate Difference Accounting Rules

The current rules for accounting for exchange rate differences have been extended until 2027. Under this rule, exchange rate differences arising at the end of the month are included in expenses/income only at the date of debt repayment (Article 272(7)(6.1) of the Russian Tax Code).

Expanded 0% Tax Rate for Publicly Traded Shares

Effective from January 1, 2025, the 0% rate applies to transactions in traded shares, regardless of the composition of the issuer’s assets, if the taxpayer sells no more than 1% of the total number of shares. Previously, this 0% tax rate was applied only if Russian real estate accounted for no more than 50% of the organization’s assets (Articles 284.2(2) of the Russian Tax Code).

Restrictions on Deductible Expenses for Corporate Income Tax

Expenses on online advertising can no longer be deducted if:

• The advertising information was not submitted to Roskomnadzor.
• The ad was placed on a restricted access resource.
• The ad was placed by a foreign entity that has not complied with Russian legal requirements. (Articles 270(44) of the Russian Tax Code).

Simplified tax system

• Increased Limits for Using the Simplified Tax System (STS)

 

• The income threshold for switching to the simplified tax system has been increased from RUB 12.5 million to RUB 337.5 million (Articles 364.12(2) of the Russian Tax Code). If a taxpayer lost the right to use STS in 2024 due to exceeding the income limit, they may reapply for STS from January 1, 2025, provided their total income for the first nine months of 2024 did not exceed 337.5 million RUB.
• The maximum average number of employees for STS eligibility has been increased from 100 to 130 (Article 346.12(3)(15) of the Russian Tax Code).
• The residual value of fixed assets has been raised from 150 million RUB to 200 million RUB. The value of Russian high-tech equipment is not included in this limit (Article 346.12(3)(16) of the Russian Tax Code).
• The income threshold for continuing to use STS has been increased from 200 million RUB to 450 million RUB (Articles 346.13(4) of the Russian Tax Code). If a taxpayer exceeds this threshold, the STS status will be lost at the beginning of the following month rather than at the beginning of the next quarter as was the case before January 1, 2025 (Article 346.13 of the Russian Tax Code).

Payment of VAT

Starting from January 1, 2025, Simplified Tax System (STS) taxpayers are required to pay VAT if their income exceeds 60 million RUB. Previously, STS taxpayers were exempt from VAT payments regardless of income level (Articles 145(1) of the Russian Tax Code). Now, taxpayers have the option to choose between:

• Applying standard VAT rates, which allows them to claim VAT deductions, or
• Applying reduced VAT rates (5% for income between 60 million to 250 million RUB per year, and 7% for income between 250 million to 450 million RUB per year), but losing the right to claim VAT deductions.

The previously used increased STS rates have been canceled. The standard rates are:

• 6% for the “income” tax base,
• 15% for the “income minus expenses” tax base

(Article 346.20 of the Russian Tax Code).

Other taxes and contributions

Tourist Tax Across Russia

Starting in 2025, a tourist tax will be introduced across all of Russia, replacing the previously existing resort fee, which applied only in certain resort regions. The new tax will apply to both organizations and individuals providing accommodation services to people in establishments listed in a special registry.

• Tax base: The cost of the service excluding VAT.
• The tax rates will be set by municipalities and may vary depending on seasonality and/or the category of accommodation.
• Certain exemptions are provided in the Tax Code for disabled individuals and veterans, and additional exemptions may be determined by municipalities.
• In 2025, the rate cannot exceed 1%. Gradual increases are planned as follows:
  • 2026 – 2%
  • 2027 – 3%
  • 2028 – 4%
  • 2029 and beyond – 5%
• A minimum tax of 100 RUB per day will apply.
• The tax will be paid quarterly, not based on the taxpayer’s registration location, but at the location of the accommodation (property).

Automated STS

The possibility of using the automated simplified tax system has been extended to all regions and will remain in effect until 2027 (Article 6 of Federal Law No. 362-FZ dated October 29, 2024).

Property tax and land tax on high-value properties

For properties taxed based on cadastre value that exceed 300 million RUB, a higher tax rate of 2.5% is introduced (Article 380(1.3) of the Russian Tax Code). Similarly, for land plots with a cadastre value exceeding 300 million RUB, the tax rate has been increased to 1.5% (Article 394(1)(1) of the Russian Tax Code).

Insurance contributions

The limit for applying reduced insurance contribution rates for small and medium-sized enterprises (SMEs) has been raised. The new limit will be 1.5 times the minimum wage (MW), instead of just the single MW (Article 427(1)(17) of the Russian Tax Code).

For SMEs in the manufacturing sector, a unified reduced insurance contribution rate of 7.6% will apply to the portion of salaries exceeding 1.5 times the MW. Centralized religious organizations will be exempt from insurance contributions (Articles 427(1)(23) and 427(2.6) of the Russian Tax Code).

Various types of state fees significantly increased

For transactions involving expensive real estate, the duty will depend on the cadaster value of the property. For legal entities, the fee may be up to 1 million RUB, and for individuals, it may be up to 500,000 RUB.

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