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CFC filings

Updated 5 October 2026

Participation and CFC notifications, financial statements of foreign companies for tax residents subject to CFC rules.

If you are a Russian tax resident and own a foreign company or control a foreign structure, the Tax Code requires notifying the tax authority of your participation and of the controlled foreign company, and sometimes paying tax on its profit. The controlled company notification is filed every year, even if the company had no activity or profit. The penalty for not filing is 500,000 roubles, about $6,000, per company. Dollar amounts use the Bank of Russia rate of 3 October 2026, about 83.5 roubles per dollar.

When a foreign company counts as controlled

• A share over 25%, directly or indirectly, together with a spouse and minor children.
• A share over 10% if all Russian tax residents together own more than 50% of the company.
• Control without a share: if you effectively decide for a company, trust, foundation or other structure without legal personality.

Which notifications are filed

• Participation in a foreign organisation: within three months after the share exceeds 10%, and when it changes. The penalty for not filing is 100,000 roubles, about $1,200.
• Controlled foreign company: annually, no later than 20 March of the year after the tax period. The penalty is 500,000 roubles per company.
• Profit documents: the company's financial statements, and if profit is exempt, documents proving the exemption. Per the tax service, for 2025 they are due by 25 March 2026.

Tax on the controlled company's profit

Without an exemption, the company's profit is included in the personal income tax return and taxed at 13% on the part up to 5 million roubles, about $59,900, and 15% above that. Non-payment of tax on this profit carries a penalty of 20% of the unpaid amount, but no less than 100,000 roubles.

When profit is exempt

• the company's annual profit is no more than 10 million roubles, about $119,800;
• the company is established in a Eurasian Economic Union country;
• the company's effective tax rate at home is at least 75% of the weighted average Russian rate, and the country exchanges tax information with Russia;
• the company is active: passive income such as dividends, interest and royalties is no more than 20%.

An exemption does not remove the duty to notify: the notification is filed with documents proving the exemption.

Foreign accounts are a separate duty

Controlled company notifications do not replace notices of opening foreign accounts and the annual reports on their flows required by currency law. If both the company and you personally have foreign accounts, you report on both fronts.

Common mistakes

• no participation notice filed when buying or setting up a company;
• indirect participation through other companies or a spouse's share ignored;
• the notification filed without financial statements or exemption documents;
• profit converted into roubles at the wrong rate.

How we work

1. Structure review: which companies and structures are controlled, which notices were already filed.
2. Company accounts: we prepare or review financial statements and an audit if required.
3. Exemption: we check whether one of the grounds applies and collect documents.
4. Notifications and return: prepared and filed on time.
5. Tax office questions: we answer requests and represent you at the inspectorate.

Preparing and filing a notification is from $830, the income tax return from $590, company accounts and audit from $950, a reply to a tax request from $470. The full list is in the table below.

Controlled Foreign Companies (CFC)

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