Publications

Federal Law No. 514-FZ, dated December 28, 2025, has introduced amendments to the regulation of settlements with a departing member of a company. In case of a dispute regarding the actual value of a share, it may now be determined based on market price, not solely on accounting records.

The member or the company itself may initiate a market-value assessment of a share upon withdrawal and on several other grounds for the transfer of a share to the company. This requires submitting an application and engaging an appraiser before the payment deadline expires.

If the assessment is not completed by the payment due date, the company pays the amount based on its accounting records but subsequently should recalculate and adjust the payment based on the assessed market value.

The amendments also allow, in principle, for moving away from valuing the company’s net assets based solely on its accounting data and enable an LLC’s charter to stipulate the use of market valuation as the default method for share valuation.

The amendments are effective from December 28, 2025.



From January 4, 2026, a new Article 1252.1 is in effect in the Russian Civil Code, establishing uniform rules for recovering compensation for infringement of exclusive rights. Compensation continues to be applied instead of damages, with the right holder exempted from proving the amount of losses.

The reform establishes three methods for calculating compensation (a fixed sum, a multiple of the value of counterfeit media or the right of use) and grants courts greater flexibility in determining its amount, taking into account the nature of the infringement and the principles of reasonableness and fairness. Specifically, it regulates cases involving multiple IP objects incorporated into a single counterfeit product and provides for the possibility of reducing compensation in cases of good-faith infringement by businesses.

These changes aim to create a more balanced and predictable liability framework for IP rights infringements while maintaining effective protection for right holders’ interests.



Effective January 1, 2026, changes have come into force permitting the Federal Tax Service (FTS) to apply security measures (a prohibition on alienation) to accounts receivable. This is a positive change for taxpayers, aimed at reducing operational risks.

Previously, if a company lacked sufficient liquid assets (real estate, vehicles), tax inspectorates could impose a prohibition on the alienation of finished goods, which paralyzed operations. Now, the FTS has a legal instrument to enforce collection against financial assets without blocking core business processes.

This norm introduces clarity and creates a more balanced procedure, allowing companies involved in disputes to maintain operational continuity by using accounts receivable as a security asset.



New rules for obtaining and confirming IT accreditation — a key condition for applying tax benefits — come into force on January 1, 2026.

In addition to introducing mandatory cooperation with an educational institution and participation in the education of IT specialists for companies with revenue over 1 billion rubles (at least 3% of the tax benefit received), strict ownership structure limitations are established.

Moreover, the right to accreditation will be retained only by non-public companies with more than 50% direct or indirect Russian control, as well as public companies not under foreign control.

For companies not meeting this criterion, the possibility of applying for a special permit from the Government of the Russian Federation is provided; however, the procedure and criteria for issuing such a permit are not established by regulation, creating significant legal uncertainty. Additionally, restrictions are introduced for state-sector companies, and detailed requirements for the official websites of IT companies are specified.



In line with global trends, from January 1, 2026, provisions are introduced into the Tax Code establishing rules for Russian members of IGCs to pay corporate income tax in an amount necessary to achieve an effective tax rate of no less than 15%. The specifics of calculation and payment will be regulated by a new Article 288.5 of the Tax Code and include several key conditions:

• The group’s consolidated income (revenue) exceeds the established threshold (equiv. 750 million euros);
• The IGC’s parent company is a tax resident of a foreign state;
• The IGC structure includes resident companies of jurisdictions from special lists of the Russian Ministry of Finance;
• The calculated tax load ratio of the IGC member is less than 0.15 (15%).

These new provisions require companies belonging to large international holdings to conduct comprehensive tax analysis and prepare for new calculations.



The Russian Prosecutor General’s Office has expanded the scope of prosecutorial supervision, requiring prosecutors to pay increased attention to compliance with counter-sanctions restrictions by foreign companies and entities with foreign participation. Particular focus will be placed on monitoring foreign trade transactions, currency operations, and court disputes involving foreign elements, as well as the targeted use of budgetary funds. This development indicates a further tightening trend in the control of cross-border operations.



The Russian Government has approved a list of 54 sectors where small and medium-sized enterprises (SMEs) will retain the right to apply a reduced social security premium rate of 15% in 2026.

The list includes key economic sectors such as manufacturing, agriculture, IT, science, tourism, and others. For SMEs in the manufacturing sector that derive at least 70% of their total revenue from manufacturing activities the rate will remain at 7.6%. The benefit applies both within and above the maximum contribution base.



The Federal Tax Service of Russia has postponed the implementation of the system for automated determination of tax residency for individuals from the end of 2025 to the period 2027–2031.

Until that time, the current procedure remains in place, whereby confirming residency status often requires taxpayers to provide additional documents beyond passport stamps, due to the possibility of passing automated border control at some airports or traveling to/through neighboring countries using an internal passport without receiving stamps.



Following a meeting of the Council for Strategic Development, the President of the Russian Federation instructed the Government and the Bank of Russia to achieve a significant increase in tax collection in 2026. The key instrument should be an action plan for the “formalization” (bringing into the “white” economy) of certain economic sectors, the effectiveness of which will be assessed based on achieving 2021 indicators.

The measures are aimed at creating favorable conditions for bona fide market participants and bringing shadow turnovers out of the “grey” zone. In practice, this means not only incentive measures (such as benefits for SMEs) but also tighter control and counteraction against tax avoidance schemes.

A report on the plan’s implementation must be submitted by June 1, 2026.