The new FTS order approving the list of states that do not provide for information exchange applies starting from the 2025 tax period

25 / 02 / 2025

On 31 December 2024, the Federal Tax Service of Russia Order No. ED-7-17/914@ dated 30 October 2024, “On Approval of the List of States That Do Not Provide for the Exchange of Information for Tax Purposes with the Russian Federation,” entered into force. The new “blacklist” is significantly broader than the previous one, as it additionally includes 26 EU member states.

In this regard, on 18 February 2025 the Federal Tax Service issued Letter No. ShYu-4-13/1583@, “On the Period of Application of Orders Approving the List of States That Do Not Provide for Information Exchange.” It clarifies that the Order is to be applied starting from the 2025 tax period when determining the tax base for CFC profit tax for the financial year ending in 2024.

As for determining the tax base for the 2024 tax period under the relevant tax in respect of CFC profit for the 2023 financial year, Federal Tax Service Order No. ED-7-17/914@ dated 1 December 2023 still applies. This means that an audit of the financial statements for 2023 for CFCs located in states not included in the FTS’s old list is not required.