Foreign organizations which are registered as tax payers in Russia, but do not operate a legal entity in the country, are required to disclose information about their shareholders starting from May 20th 2021. This applies to organizations such as foundations, partnerships, trusts and cooperatives. So far a similar reporting requirement has applied only to foreign owners of taxable real estate.
The disclosure of shareholder information applies to shareholders with over 5 % of shares in the organization. Foreign organizations which are registered as providers of electronic services are exempt from the new rule.
The first reporting deadline according to the new requirement is March 28th 2022, at which time shareholder information as of December 31st 2021 has to be reported. The March 28th deadline will apply for each year annually afterwards as well. However, the Russian tax authorities and the financial monitoring organ are allowed to request such information at any time, and the receiver of such a request is obliged to report this information within 5 days of the request.
Failure to report or late submission of reports results in a 50 thousand ruble fine, which is why it´s advisable to prepare information according to the new reporting requirement in advance.
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