Russia has published Law No. 325-FZ of 29 September 2019 on amendments to Parts One and Two of the Russian Tax Code. The law includes various amendments, including:

• New rules on mutual agreement procedures (MAP) in accordance with BEPS Action 14;
• A three-year statute of limitations for claiming a refund of overpaid corporate income tax;
• Amendments to the procedures for asset amortization and depreciation, including that the depreciation method may not be changed more than once every 5 years;
• Rules requiring VAT obligation continuity after a corporate reorganization;
• Mandatory electronic tax filing for companies with ten or more employees;
• Rules for the treatment of after-tax profits distributed by a non-resident subsidiary to a Russian company as dividends subject to corporate income tax, regardless of the classification of the payment in the source country;
• Rules allowing the offset of overpaid tax amounts against any type of tax (federal, regional or municipal); and
• Extension of the current 50% carried forward loss offset limit so that it applies to 31 December 2021.

The amendments generally enter into force on 1 January 2020.