In January 2017 Russia Has Joined the Multilateral Competent Authority Agreement on the Automatic Exchange of Country-by-Country Tax Reporting  https://2018.biia.com/transparency-russia-has-joined-the-multilateral-competent-authority-agreement-on-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 http://www.credinform.ru/en-US, 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 https://globas.credinform.ru/en-US/home/auth covering data on Russian public and private companies.