Russian CFC notification in 2026: deadlines, form, no profit

No profit - the notification is still required, and missing it costs 500,000 rubles per company. We cover who must file a Russian CFC notification, the 2026 deadlines for individuals, the form, documents, exemptions, tax and fines.

In detail

A Russian CFC notification is filed by every Russian tax resident who controls a foreign company, even if it made no profit at all. Individuals file it for 2025 by 30 April 2026, and missing it carries a fine of 500,000 rubles, about $5,900, per company. Tax on the profit is only paid if the company's profit for the year exceeds 10 million rubles.

Below, in plain words: who must file, how the CFC notification differs from the participation notification, the 2026 deadlines, what to attach, what to do if there is no profit, and how the tax is calculated. We prepare and file notifications as part of our CFC notifications and reporting service.

What a CFC is in plain words

A CFC is a controlled foreign company. The Russian Tax Code uses the term for a foreign company or a structure without legal personality - a foundation, trust or partnership - controlled by a Russian tax resident. The point of the rules is to stop profit kept abroad from escaping Russian tax: if the company does not distribute profit, the owner still includes it in their own tax calculation.

A CFC is not prohibited and does not automatically mean tax. A company in Cyprus, the UAE or Kazakhstan may be a CFC and create no tax obligations for its owner except one - the annual notification.

Who must file a CFC notification

A Russian tax resident is a controlling person if at least one condition in the table is met. Stakes are counted together with those of the spouse and minor children.

Citizenship does not matter: tax residency does. Anyone who spent 183 days or more in Russia in a calendar year remains resident and files the notification. A foreigner who has become a Russian tax resident must file it too.

The CFC notification and the participation notification: the difference

They are often confused, although they are two different documents with different deadlines and fines.

The participation notification is filed once for each change, while the CFC notification is filed every year, even if nothing has changed.

How to calculate the stake and control: examples

It is not only the direct stake that counts. If you own a company that owns another company, the indirect stake is calculated by multiplying the stakes along the chain. And the stakes of your spouse and minor children are added to yours.

Actual control counts even without a stake: for example, if under a contract or through nominee directors you decide how the company's profit is distributed.

Example: a UAE company and a Cyprus company

Take an owner of two companies, in the UAE and Cyprus. Both are their CFCs, and they file a notification for both by 30 April. Everything else depends on profit and exemptions.

• The UAE company earned 6 million rubles. That is below 10 million, so there is no Russian tax, but the notification and statements are required.
• The Cyprus company earned 30 million rubles. The profit exceeds the threshold, so exemptions are checked: if the effective tax rate in Cyprus is below 75% of the weighted average Russian rate and the company is not active, the profit goes into the return and is taxed at 13-15%.

The choice of country for a company affects a Russian owner's taxes more than it seems. We register companies in the UAE company and Cyprus company sections.

How to file through the taxpayer account: step by step

1. Collect each company's financial statements for the financial year and, if needed, the auditor's report.
2. Translate the documents into Russian.
3. Calculate the stake, including indirect, and choose the basis of control.
4. Fill in the notification for each company, stating the profit or the basis for exemption.
5. Sign and send the notification through the taxpayer's personal account, attaching the documents.
6. If profit exceeds 10 million rubles and there is no exemption, file a return by 30 April and pay the tax by 15 July.

After filing, keep the receipt: if the tax office sends a request for explanations, you must reply within the deadline stated in it.

CFC notification deadlines in 2026

For individuals the key date is 30 April: by then they file both the CFC notification and, if needed, the return with CFC profit. Companies file the notification earlier, by 20 March.

The notification is filed for the calendar year in which the company's financial year ended. If the company's financial year differs from the calendar year, profit is taken for the year that ended in the reporting calendar year.

The CFC notification form and how to fill it in

The form is approved by the Federal Tax Service. It is filed with the tax office at your place of residence: through the taxpayer's personal account, by post or in person. The notification states:

• your details as the controlling person;
• the name, registration number and country of each company;
• your stake and basis of control: direct ownership, indirect or actual management;
• the start and end dates of the company's financial year;
• the profit or loss per the financial statements, or the basis for exemption.

Each CFC is shown separately. If there are several companies and one owns another, the indirect stake is calculated by multiplying stakes along the chain. This is where mistakes happen most often: a miscalculated stake turns the notification into a document with false information, and the fine for that is the same as for not filing.

What to attach to the notification

• The company's financial statements for the financial year, prepared under the laws of its country.
• An auditor's report if an audit is mandatory under the country's law or the articles, or was carried out voluntarily.
• Exemption documents - if the company's profit is exempt from Russian tax, proof of the basis is attached instead of the statements.
• A Russian translation of documents in a foreign language.

There is an important detail for countries without a double tax treaty with Russia, such as the British Virgin Islands. The profit of such a company is calculated from its statements only if there is an auditor's report without an adverse opinion. Without an audit, profit is recalculated under Russian corporate tax rules, which takes longer and usually costs more. More on the BVI accounts and audit and Cyprus company audit pages.

The CFC notification if there is no profit

No profit - the notification is still needed. This is the most common question and the most expensive mistake: many think a loss-making or dormant company is exempt from reporting and get a 500,000-ruble fine.

• A loss or zero. The notification is filed; no return with CFC profit.
• Profit up to 10 million rubles. The notification is filed, the profit is not taxed, and no return is filed because of the CFC.
• Profit above 10 million rubles. Both the notification and the return are filed, and tax is paid unless another exemption applies.
• A company with no activity. Financial statements or documents confirming a nil result are still needed.

Past losses can be carried forward to reduce future profit, but for that they must also be shown in the notifications for each year.

When CFC profit is not taxed

The Tax Code lists grounds on which CFC profit is exempt from Russian tax. The notification is still filed, with documents proving the ground attached.

• Profit for the year of no more than 10 million rubles - the simplest and most common ground.
• A company from a Eurasian Economic Union country - Kazakhstan, Kyrgyzstan, Armenia or Belarus - provided it is permanently located there.
• Effective tax rate of the company in its country of at least 75% of the weighted average Russian rate, with the country exchanging tax information with Russia.
• An active company - passive income such as dividends, interest and rent makes up no more than 20% of all income.
• Certain types of company - non-profits that do not distribute profit, banks and insurers, bond issuers and several other cases in the law.

Each ground has its own documents. The effective rate needs a calculation of the tax in the company's country, an active company needs a breakdown of income by type. They are prepared in advance because they are attached to the notification by 30 April.

Tax on CFC profit: 13-15% or a fixed amount

If CFC profit exceeds 10 million rubles and there is no exemption, the owner includes their share of the profit in the return. The tax is 13% on the part up to 5 million rubles and 15% above it. Profit is reduced by dividends the company paid, and the tax already paid by the company abroad and in Russia is deducted from the tax.

There is a second route - tax on fixed profit. The owner pays a known amount and does not calculate each company's profit. The switch is declared by 31 December of the year the tax is paid for, with a commitment to stay in the regime for at least five years. CFC notifications continue to be filed.

The fixed tax pays off only with very large company profits: with modest profit the standard procedure with its 10-million-ruble threshold is almost always cheaper.

CFC fines

Fines are counted per company and per year. With three companies and two years without notifications, the total quickly exceeds the cost of any document preparation.

How the tax office learns about CFCs

The tax office sees foreign companies not only from notifications. Information comes from reports on foreign account movements, from participation notifications, from automatic data exchange with the countries that still carry it out, and from Russian banks' records of transfers abroad. When the data disagree, the office sends a request for explanations, which must be answered on time. It is simpler and cheaper to file the notification on time than to explain why the company was found without one.

CFCs and moving abroad: if you are no longer a Russian resident

The CFC rules apply only to Russian tax residents. If you spent fewer than 183 days in Russia in a calendar year, you are a non-resident and do not file a CFC notification for that year. But the obligation for the years you were resident remains, and the notification for the last year must be filed even after the move.

The participation notification is a separate matter: if your stake changed while you were resident, it is filed too. Exactly when you stop being resident and what other obligations remain is covered in our articles on Russian tax non-residents and the 183-day rule.

Common mistakes in the CFC notification

1. Not filing because there is no profit. The notification is needed with any profit and with a loss.
2. Confusing the participation notification with the CFC notification. They are two documents with different deadlines and fines.
3. Miscalculating the indirect stake in a chain of companies and reporting false information.
4. Forgetting about foundations and trusts. A structure without legal personality can also be a CFC.
5. Attaching statements without a translation or without an auditor's report when an audit is mandatory.
6. Ignoring the spouse and children. Their stakes are added to yours when control is calculated.
7. Not filing after moving abroad the notification for the last year of residency.

How much preparing a CFC notification costs

The state charges nothing for filing the notification. The costs are preparing the company's statements, an audit if needed, translating documents, and preparing the notification and the return.

The total depends on the number of companies, the country, whether there is an audit and whether a return is needed. For several companies and structures with ownership chains we quote after reviewing the documents.

How we help

The law does not stop you from filing the notification on your own. But mistakes cost more than any preparation: an unfiled notification for a loss-making company, a miscalculated indirect stake, statements without an audit where one is needed to calculate profit, a missed participation notification, tax under Russian rules instead of the company's statements. We identify which companies are your CFCs, check exemptions, prepare statements and translations, fill in and file the notification and return, and reply to tax office requests.

Owners of foreign accounts will find our guide to the foreign account cash flow report useful, and those choosing a country for a company - our reviews of countries with no income tax, taxes in the UAE and taxes in Cyprus. How to avoid paying tax twice is covered in our article on double taxation.

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