Starting from 2022 UBO Reporting in Russia will be required for all foreign companies.
Russian subsidiaries of foreign companies are already required to maintain and annually update the UBO file. A new requirement is that all foreign companies registered with the Russian tax authorities (i.e., having branches or representative offices in Russia) will be obliged to annually submit information about their participants (founders, beneficiaries and managers). This information must be provided to the tax authorities at the place of tax registration starting from 2022. The extended obligation was implemented into item 3.2. Art. 23 Tax Code RF by the Federal Law No. 100-FZ of April 20, 2021.
Information shall disclose direct and indirect participation (if any) of an individual or a public company, if the share of their direct or indirect participation exceeds 5%.
The deadline for UBO reporting in Russia (providing the status as of 31 December of the preceding year) is March 28 of each year. Hereto first UBO submission for foreign companies shall be done no later than March 28, 2022. It is often a lengthy process to establish a UBO file and gather the corporate approvals for its disclosure among foreign holding structures. Therefore, we recommend to start preparing the UBO information well in advance and will be glad to provide our assistance in this matter.
We are awaiting the clarification of the tax authority on the submission and respective documents and will keep you updated on the next developments.