Among such criteria, the following were mentioned:

• Total income over 2 years exceeding RUB 500 million. For assessment purposes, the periods considered will not necessarily have to be consecutive — this is intended to exclude situations where income declined in a particular year due to an unsuccessful transaction or a financial crisis, and the taxpayer would otherwise fall outside tax control.

• Ownership of controlled foreign companies (CFC). According to the Federal Tax Service, this criterion may apply independently of the previous one (i.e., even if income for a given period is less than RUB 500 million.

• Ownership of large foreign accounts and other foreign assets. Here the Federal Tax Service plans to rely on information received annually under the automatic exchange of information (CRS).

• Total family income exceeding a specified amount for a given period.

For now, this is only an indicative list of criteria mentioned by Yulia Shepeleva, Deputy Head of the Federal Tax Service. However, even now the logic of the law enforcement authority can be discerned:

• The criteria for classifying individuals as ultra-high-net-worth are formulated broadly enough to avoid a purely formal approach — for example, income amounted to RUB 450 million rather than RUB 500 million, and therefore such a taxpayer would not be subject to more intensive tax control. This gives the tax authority the ability to assess each such taxpayer individually.

• Significant emphasis is placed specifically on foreign assets — those for which it is most difficult for the Federal Tax Service to track information in a timely manner: CFCs, foreign accounts, overseas real estate. The inclusion of foreign companies and structures in this list is not accidental: it is assumed that their profits and assets will be taken into account when assessing the taxpayer's wealth.

• Assessment of total family income: this is intended to exclude situations where the income and assets of a particular individual would be evenly distributed among members of a large family, and none of those members would meet the formal criteria for being classified as ultra-high-net-worth.

• It is obvious that taxpayers assigned to the new inspectorate will be subject to more thorough tax control than before. The original purpose of creating such a tax inspectorate is precisely to consolidate the experience of inspectors working with large incomes and foreign-source income — it is believed that this will make it easier to ensure tax revenues to the budget in the proper amount.
  
  

We would be pleased to advise you in more detail on the expected changes and, if you are registered as a major taxpayer, to work with you to develop a new tax strategy.