Moscow, Russia

Disclosure obligations for foreign entities in Russia extended in 2022

By Valeria Khmelevskaya, KBK Accounting

Based on Russia’s federal law No. 115-FZ On Anti-Money Laundering and Combating the Financing of Terrorism, the majority of Russian companies are obliged to maintain and update a register of beneficial owners, but such information may be disclosed only upon request of the competent state bodies – tax authorities, Rosfinmonitoring (the Russian Federal Financial Monitoring Service), banks, etc.

Starting in 2022, the obligation to regularly report on such information to tax authorities applies to all foreign companies registered with Russian tax authorities; the only exception is made for providers of electronically supplied services. Previously this obligation existed only for foreign entities that owned real estate in Russia. Relevant notifications are to be submitted by foreign companies by filing a statutory form no later than on 28 March of the relevant following year (so for example, in 2022 companies have to report on 2021). Foreign entities must disclose information regarding:

  • their direct shareholders;
  • the structure of indirect participation in the foreign entity of individuals or public companies (when participation of the latter exceeds 5%).

Failure to meet the filing obligation will be sanctioned with a fine of RUB 50,000 (approx. EUR 400). Notably, there is still no public register of ultimate beneficial owners (UBOs) in Russia, and no such information can be found in Russia’s Unified Register of Legal Entities.

Valeria Khmelevskaya

Valeria Khmelevskaya

GGI member firm
KBK Accounting
Auditing & Accounting, Tax
Moscow, Russia
T: +7 495 662 33 30
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KBK Accounting is a reputable outsourcing firm and provider of a wide range of services, including tax accounting and bookkeeping, tax advisory, reporting and compliance, HR, and interim management.

Valeria Khmelevskayais a Partner, Lawyer, and Tax Consultant admitted to practice in Russia. She has over 20 years of experience of consulting in matters of Russian and international tax law. Ms. Khmelevskaya is also the Deputy Head of the Management Board and the Chair of the Committee for Taxes and Financial Reporting of the German-Russian Chamber of Commerce (AHK) and recommended attorney of the Austrian Foreign Trade Centre Moscow (Advantage Austria).

Published: International Taxation Newsletter, No. 16, Spring 2022 l Photo: Dmitry -


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