1. Bank of Russia Lowers Key Rate to 16.5% Per Annum
The Board of Directors of the Bank of Russia, at its monetary policy meeting on October 24, 2025, decided to reduce the key rate to 16.5% per annum. The new rate is effective from October 27, 2025.
The regulator has indicated that its future decisions on the key rate will depend on the sustainability of the slowdown in inflation and the dynamics of inflation expectations. The next meeting to review the key rate is scheduled for December 19, 2025.
2. Supreme Court Approves New Review of Practice for Commercial Disputes
On October 8, 2025, the Presidium of the Russian Supreme Court approved Review of Court Practice No. 3 (2025), which contains key legal positions on cases reviewed by its Judicial Panel for Economic Disputes.
Of particular interest is the clarification that a decision of a company’s general meeting of participants cannot be deemed void solely due to the lack of notarization, provided it is proven that the decision was actually adopted and executed by the participants. The Supreme Court stated that if all participants took part in adopting the decision and there are no reasonable doubts about this fact, the absence of notarization does not render the decision null and void. The Court also noted that a person who, by their actions, has created reasonable expectations among other persons regarding the validity of the decision (e.g., through partial execution of the challenged decision) is not subsequently entitled to challenge its validity. A claim by such a person that the decision is void, if made contrary to their prior consistent conduct, shall have no legal effect.
Furthermore, the Review highlights other corporate law matters:
- In disputes concerning the payment of the actual value of a share to a withdrawing participant, the burden of proving that the company's debt is genuine (and not artificially inflated) rests with the company itself if there are indications of such artificial inflation.
- If the price in a sale and purchase agreement was a subject of negotiations between the parties, it becomes an essential term of the contract and cannot be supplemented or determined by the court.
The new clarifications from the Supreme Court reinforce the principles of good faith and consistency of conduct in corporate and contractual relations.
3. Marketplaces to be Obliged to Report Tax Risks of Their Partners
A new system for information exchange between digital platforms and tax authorities is being prepared in Russia. The relevant provisions are contained in Federal Law No. 289-FZ dated July 31, 2025 “On the Regulation of the Platform Economy”, which will come into force on October 1, 2026.
This law provides, among other things, for interaction between digital platform operators and tax authorities. A draft government resolution, published in October, specifies that operators of marketplaces and other intermediary platforms will be required to notify the tax authorities of identified signs of violations of tax legislation by their partners. The Federal Tax Service (FTS) of Russia will approve the list of such risks and the procedure for their identification. The information must be transmitted within five days of identification, and details of the risk will be simultaneously reflected in the partner’s personal account on the marketplace.
Furthermore, the platform operator will act as an intermediary in the interaction between the partner and the tax authorities – notifications of summons and requests for documents will be sent through the operator. Data exchange will be carried out electronically via the platforms’ information systems or FTS services.
The new requirements will take effect simultaneously with the Law on the Platform Economy – on October 1, 2026.
4. Intra-Group Services: Tax Risks Amplified by Poor Documentation
The Arbitration Court of the Vladimir Region (Case No. A11-3687/2022) upheld a tax assessment against a company that failed to prove the reality and business purpose of consulting services received from its foreign parent company. The court highlighted the lack of detailed supplementary agreements, contradictory acceptance certificates and reports, and a perfunctory approach to document flow. As a result, the payments were reclassified as dividends and subjected to withholding tax.
This case is a clear reminder that transactions between related parties remain a key focus for the Russian tax authorities, and the burden of proof for their legitimacy is high.
5. Simplified Tax Registration for Foreign Companies via Banks
Starting from September 1, 2026, the only available method for a foreign company to register with the Russian tax authorities when opening a bank account will be through the bank itself based on a simplified procedure. The tax authorities will no longer accept applications directly from foreign entities. The bank will submit the necessary documents to the tax office, which will then issue an extract from the Unified State Register of Taxpayers within five days. This change is designed to simplify and standardize the procedure.
6. Royalties in Customs Value
The practice of including royalty payments for intellectual property into the customs value of imported goods remains a high-risk area, with a growing number of disputes. A key bone of contention generally revolves around whether the entire royalty payment or only a portion attributable to the imported goods should be included in the value for customs purposes.
In September 2025, the Russian Ministry of Finance reinforced its strict position: if established conditions are met, royalties must be included in the customs value in their full amount; if not, they are excluded entirely. This “all-or-nothing” approach contradicts the developing court practice, where judges often rule that only a calculated, proportional part of the license fee relating directly to the imported goods should be taken into account when determining the customs value.
