In January 2017 Russia Has Joined the Multilateral Competent Authority Agreement on the Automatic Exchange of Country-by-Country Tax Reporting  This required the amendment of respective local laws, in particularly law No.340-FZ which was adopted 27.11.2017.

Chapter 14.4-1 was added to the Tax Code of the Russian Federation “Submission of documentation for multinational groups of companies”:

  1. Definitions of multinational group of companies and its members, Country-by-Country information and reporting, global documentation (Master File) and domestic documentation (Local File);
  2. Requirements of submissions of notification on participation in the multinational group of companies, submission of country-by-country reporting, global and domestic documentation. Penalties will be imposed on violations by financial market entities which have non-resident clients and their beneficial owners.

Chapter 20.1 “Automatic exchange of Country-by-Country Reporting with foreign countries (territories)” was added to the Tax Code which gave definitions of international automatic exchange of Country-by-Country Reporting with relevant authorities of foreign states (territories), structure of financial market and its clients, financial services and information, beneficiary, person controlling the client, financial assets and determined:

  1. Rights and obligations of financial market entities to submit information about their clients-non-residents to tax authorities
  2. Restriction on the use of information contained in the Country-by-Country Reporting.

According to the analysis performed by Credinform, there are over 300 large Russian holding companies, with revenues of over Euro 700 million, who will be required to comply with the Country-by-Country Reporting law.  Among these companies are internationally known corporations like: GASPROM, MOSENERGO, LUKOIL, Transneft, SIBERIA AIRLINES, RusHydro, URALKALI, Mining and Metallurgical Company NORILSK NICKEL, NOVOLIPETSK STEEL.

* Source: Information and Analytical system Globas covering data on Russian public and private companies.