Federal Law No. 425-FZ dated November 28, 2025 introduced numerous amendments to Part One of the Tax Code of the Russian Federation related to tax administration. The changes expand the powers of tax authorities, tighten audit procedures (including desk audits), modify the rules for granting tax deferrals, and adjust the approach to tax penalties and interest. Below is an overview of the key developments taxpayers will face in 2026, with some provisions entering into force later.
Prior to 2026, desk tax audits could only be conducted by the tax office to which the tax return or calculation had been submitted. Starting in 2026, this rule changes. Desk audits may now be carried out by any tax authority authorized by the Federal Tax Service of Russia. Corresponding amendments were introduced to paragraph 1 of Article 88 of the Tax Code.
Taxpayers must be notified of which authority will conduct the audit. Notifications may be sent by registered mail, via telecommunications channels, through the taxpayer’s personal account, or through the Unified Portal of Public Services. During a desk audit, taxpayers may submit explanations and supporting documents either to the authorized tax authority or to the tax office where the return was originally filed.
As for field audits, the period subject to review has also been expanded. Previously, tax authorities could review no more than three calendar years preceding the year in which the audit decision was issued, unless amended tax returns were filed. From 2026, tax authorities may also audit completed tax periods of the current year for taxes with a reporting period of less than one year. These changes apply only to periods that have already ended by the date the audit decision is issued.
The Tax Code has been amended to formalize the procedure for summoning individuals to provide testimony. From 2026, any individual who may possess information relevant to tax control measures may be summoned. Notifications may be delivered by registered mail, electronically via telecommunications channels, through the taxpayer’s personal account, through the Public Services portal, or personally against signature.
The scope of circumstances allowing inspections of a taxpayer’s premises or territories has also been expanded. Previously, inspections were permitted only during tax audits or tax monitoring. From 2026, inspections will also be allowed during additional tax control measures, provided that tax officials present official identification and a formal decision authorizing such measures.
Before the amendments, organizations were required to submit notifications on personal income tax (PIT) and insurance contributions twice per month. Starting September 1, 2026, taxpayers may submit a single annual notification covering PIT and insurance contributions for the entire year. Updated notifications will only be required in cases of changes affecting tax amounts, such as employee termination, illness, or unplanned leave.
Taxpayers may continue to use the current twice-monthly notification procedure if preferred. In addition, starting in 2027, organizations will no longer be required to submit notifications for calculated property taxes. From that year, tax authorities will independently calculate transport tax, land tax, and corporate property tax and will send payment notices to taxpayers.
Federal Law No. 425-FZ introduces limitations on using positive balances of the Unified Tax Account (UTA) to pay taxes for third parties. From September 1, 2026, taxes may be paid for third parties only if such parties have an actual obligation to pay the respective tax or contribution.
If no such obligation exists, the offset request will be rejected. In addition, paying taxes for third parties via the taxpayer’s personal account will require a qualified electronic signature. These changes significantly restrict the previously flexible practice of third-party tax payments.
From September 1, 2026, new limits will apply to the reduction of tax penalties in the presence of mitigating circumstances. While current rules set only a minimum reduction threshold (at least a twofold reduction), the amended legislation establishes both minimum and maximum limits.
Under the new rules, penalties must be reduced by at least two times and no more than ten times compared to the statutory amount. Tax authorities and courts will be required to take into account mitigating circumstances approved by the Federal Tax Service when determining penalty amounts.
Starting September 1, 2026, organizations and individual entrepreneurs facing financial difficulties will be able to apply for tax deferrals or installment plans under a simplified procedure. Applicants will no longer be required to submit bank statements confirming account balances and turnover, as tax authorities will obtain this information directly from banks.
However, taxpayers must still submit an application, a list of debtor counterparties, and documents confirming the grounds for the deferral. As before, collateral, a guarantee, or a bank guarantee will be required.
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