Publications

The Russian Constitutional Court has ruled that Articles 248.1 and 248.2 of the Commercial Procedure Code, key laws protecting Russian companies from sanctions-related damages, cannot be applied automatically. The court clarified that granting anti-suit injunctions or claiming damages requires establishing the exclusive jurisdiction of Russian courts and a comprehensive examination of all case circumstances, not merely the involvement of a sanctioned party. This decision challenges the recent formalistic judicial practice and emphasizes the need to balance the rights of all parties in such disputes.



The Board of Directors of the Bank of Russia, at its monetary policy meeting on December 19, 2025, decided to reduce the key rate by 50 basis points to 16.00% per annum. The new rate is effective from December 22, 2025.

The regulator cited signs of moderating inflation and a gradual return of the economy to a balanced growth path. It emphasized that monetary policy will remain tight to ensure a sustained return to the 4% inflation target, with the next key rate decision scheduled for February 13, 2026.



Effective December 8, 2025, the Bank of Russia is eliminating limits on foreign currency transfers abroad for Russian citizens and individual non-residents from the so called “friendly” countries. Restrictions remain in place for non-residents from “unfriendly” countries not working in Russia, as well as for legal entities from these states, except for companies controlled by Russian persons. The change reflects stabilization in the foreign exchange market and a partial liberalization of cross-border transactions.

The prohibitions do not apply to operations involving the transfer of funds by foreign investors from type “In” (investment) accounts to accounts abroad.



The Presidium of the Supreme Court of the Russian Federation has approved a review of judicial practice concerning the imposition of subsidiary liability on controlling persons for the debts of inactive legal entities. The Court has broadened the interpretation of the term “inactive legal entity” to include companies that have de facto ceased operations. A presumption of guilt has been established for controlling persons who evade providing documents, and the possibility of holding nominal directors liable has been confirmed.

This interpretation strengthens the position of creditors and indicates a tightening of judicial practice, requiring increased diligence from beneficial owners and directors.



The Federal Antimonopoly Service (FAS) of Russia has presented model practices for interaction between marketplaces, rights holders, and sellers to protect intellectual property. The document, which is advisory in nature, proposes mechanisms such as verifying sellers’ documents before listing goods and a “red flag” system for identifying counterfeits. Procedures for blocking unscrupulous sellers and creating a unified information system for recording cases of counterfeit goods are also described.



A law introducing large-scale changes to the Tax Code has been adopted.

VAT: Rate and Benefits
From January 1, 2026, the standard VAT rate increases from 20% to 22%. This will affect most transactions not eligible for benefits. The preferential 10% rate for socially significant goods is retained, as are reduced rates (5%, 7%) for a number of operations.

Simplified Taxation System: New Limits
For entities using the Simplified Taxation System, the income threshold for mandatory VAT payment will be gradually reduced: from 60 million to 20 million rubles in 2026, and further to 10 million rubles by 2028.

Technology Levy
From September 1, 2026, a levy on the import and production of electronics (up to 5,000 rubles per unit) is introduced. This is a direct cost factor that will most likely lead to an increase in retail prices for a wide range of electronic devices.

Other Significant Measures
Important administrative mechanisms are also extended for 2026:

• Special procedure for calculating penalties for tax arrears;
• Accelerated declaratory procedure for VAT refund.

Federal Law No. 425-FZ has adjusted the conditions for applying reduced rates of insurance premiums. The right to a preferential 15% rate for SMEs will be restricted to priority sectors, the list of which is to be approved by the

Russian Government. Rates for IT companies have been changed, and a zero rate for organizations in the radio-electronic industry has been reinstated. Benefits for non-profit and charitable organizations are extended until 2036, but with increased rates.



The Federal Tax Service (FTS) of Russia has begun mass mailing of inquiries to owners of accounts in the UAE based on data from automatic exchange of information. The inquiries concern the origin of funds, confirmation of tax residency, and activities of companies controlled by said accounts owners in the UAE. The measure is related to the upcoming entry into force on January 1, 2026, of the agreement on the avoidance of double taxation between the countries. Violations may lead to additional personal income tax assessments, fines, and currency sanctions.



From January 1, 2026, the “counterparty analysis service” will receive official status. It allows obtaining analytical reports based on more than 50 parameters, which can be used as evidence of “due diligence” for KYC purposes. However, the FTS notes that the report is not a guarantee of protection from claims, especially in cases of intentional tax evasion.