EN

RU CN

Date:

14.03.2026

Reading time:

3 minutes

Author:

Daniil Kadyrov

Managing Partner

Reporting on Controlled Foreign Companies and the Importance of Reliable Service Providers

Tax Law Corporate Law International Law UBO Tax accounting Legal support

Date:

14.03.2026

Reading time:

3 minutes

FAQ

What should be done if tax reporting was submitted with errors?

It is necessary to promptly submit a corrected notification and revised documents. Voluntary correction reduces the risk of sanctions.

Is audited reporting required to be attached to the CFC notification in Russia?

No, as a general rule ordinary financial statements translated into Russian are sufficient. However, in some cases the tax authority may request a certified translation or an audit report.

In which cases is it allowed not to attach CFC reporting in Russia?

If the company is exempt from taxation of its profits in Russia (for example, if it meets the criteria of a small CFC or falls under other exemptions provided by the Tax Code of the Russian Federation).

Who is liable for failing to submit tax reporting in Russia?

Liability is borne by the tax resident of the Russian Federation who controls the foreign company.

How often must CFC reporting be submitted in Russia?

Reporting is submitted annually together with the notification on controlled foreign companies.

What should be done if the foreign company’s accountant did not provide the reporting?

It is necessary to promptly engage another specialist or consultant to prepare and translate the documents. Evidence that the entrepreneur took measures to obtain the reporting may be relevant when the tax authorities consider the case.

What is the penalty for failing to submit CFC reporting in Russia?

The penalty for failing to submit translated financial reporting together with the notification is 500,000 rubles for each company.

What documents must be attached to the CFC notification in Russia?

The notification must be accompanied by the foreign company’s accounting statements translated into Russian. In some cases, tax authorities may request supporting audit documents or registration information.
All questions and answers

Key Terms

C

CFC Notification

A document that a tax resident of the Russian Federation is obliged to submit annually to the tax authority if they have controlled foreign companies. It contains information about the company, its financial statements, and the controlling persons.

C

Controlled Foreign Company (CFC)

A foreign organisation or a structure without legal entity status that is recognised as controlled if a tax resident of the Russian Federation directly or indirectly owns more than 25 percent of participation (or more than 10 percent provided that the combined participation of all tax residents of the Russian Federation exceeds 50 percent), or exercises actual control over its activities. The profit of a CFC is subject to taxation in Russia in accordance with the Tax Code of the Russian Federation.

C

Controlling Person

An individual — a tax resident of the Russian Federation — who directly or indirectly owns or controls a foreign company and is obliged to notify the tax authority of its activities and pay tax on the profit of the CFC.

F

Federal Tax Service of Russia

A federal executive authority responsible for supervision and control over compliance with legislation on taxes and fees, ensuring correct calculation and timely payment of taxes, fees, and insurance contributions, as well as the application of special tax regimes.

I

Interregional Inspectorate of the Federal Tax Service of Russia for Major Taxpayers

A federal executive authority responsible for developing state policy and regulatory framework in the field of the budget, taxes and fees, insurance contributions, as well as financial markets and international cooperation.

M

Ministry of Finance of the Russian Federation

A state authority authorised under the legislation to supervise the correctness of calculation and payment of taxes and fees, to review taxpayers’ reporting, and to apply measures of liability for tax offences.

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