Russia has published Federal Law No. 100-FZ of 20 April 2021 in the Official Gazette, which includes various amendments to parts one and two of the Russian Tax Code. One of the main amendments is made to Article 23 (Obligations of Taxpayers), which includes the addition of new provisions regarding the disclosure of beneficial ownership information that apply from 1 January 2022.
The new provisions require foreign organizations (legal entities) and foreign structures not formed as legal entities that are registered for tax purposes in Russia to annually submit information concerning their beneficial owners (participants, founders, managers, and other beneficiaries) to the tax authority of their place of registration. The disclosure of information is also required in relation to indirect participations, if any, where the combined share of indirect and direct participation in the foreign organization exceeds 5%. However, it provided that the requirements do not apply for a foreign organization that is only required to register for tax in Russia on the basis of paragraph 4 of Article 83, which includes registration when providing electronic services to individuals in Russia.
When required, the information must be submitted by 28 March in regard to the beneficial owners as on 31 December of the year preceding the year in which the information is submitted. If a foreign organization is registered with multiple local tax authorities, the information only needs to be submitted to one local tax authority at the option of the foreign organization. Failure to submit or late submission will be subject to a fine of RUB 50,000.