Dear corporate taxpayers, we draw your attention to an important upcoming reporting deadline.
By 20 March 2026, organizations are required to submit to the tax authority a Notification on Controlled Foreign Companies (CFC) for the fiscal year 2025.
Please note: The notification must be submitted regardless of the financial result of the foreign company’s activities — whether it reported a profit or a loss.
The CFC Notification (using the form approved by the Federal Tax Service Order dated 19.07.2021 No. ЕД-7-13/671@).
If there are grounds for exempting CFC profits from taxation — supporting documents confirming that the conditions for such exemption are met.
Exception: Companies incorporated in EAEU (Eurasian Economic Union) member states are exempt without the need for additional confirmation.
If no grounds for exemption exist, documents confirming the amount of profit (or loss) of the CFC must be submitted by 25 March, together with the corporate income tax return.
This requirement applies regardless of whether the profit amount qualifies for the tax exemption under Clause 7, Article 25.15 of the Russian Tax Code (НК РФ).
Failure to submit the CFC notification carries a penalty of 500,000 rubles.
Individuals are required to submit the CFC Notification for 2025 to the tax authority no later than 30 April 2026.
Detailed information on the criteria for recognition as a controlling person, the procedure for submitting the CFC notification, and the list of supporting documents is available in the dedicated section of the Federal Tax Service (ФНС России) website: “Controlling Persons and Controlled Foreign Companies.”
CFC reporting obligations can be complex, and deadlines approach quickly. We strongly encourage you not to delay preparation.
If you have questions about CFC notification requirements, exemption conditions, or supporting documentation, we are here to help. Please reach out to us at info@sterngoff.com — we will be happy to assist you in meeting your obligations accurately and on time.
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