A Russian LLC (OOO) if it qualifies as a member of an MNE Group under the criteria set out in Article 105.16-1 of the Russian Tax Code (TC RF):
The LLC is part of a group of entities connected through capital participation;
consolidated financial statements for the group are prepared in accordance with other internationally recognized accounting standards;
and the group’s consolidated revenue for 2023 (the financial year preceding the reporting year) exceeds the threshold set in the country of tax residence of the group’s parent company (most often EUR 750 million).
An MNE Group member must submit the notification electronically only, no later than eight months after the end of the reporting period of the parent company (paragraphs 1 and 4 of Article 105.16-2 TC RF).
If the group’s reporting period ends on December 31, 2024, the notification must be submitted no later than August 31, 2025 by one of the MNE Group members, containing information about the entire group.
Penalties for missing the deadline
Failure to submit the notification, submitting it later than eight months after the end of the reporting period of the parent company, or submitting it with errors or inaccuracies will result in a fine (Article 129.9 TC RF) of RUB 500,000 for each violation.
How we can help
Our transfer pricing (TP) experts are ready to assist you in preparing and submitting the Notification of Participation in an MNE Group and other country-by-country reports in compliance with Russian legislation.
📩 For inquiries, please contact audit@sterngoff.com with the subject line: “Notification of Participation in an MNE Group”
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