News

Changes to the Tax Code of the Russian Federation in 2026 (Part 3)

In this review, we would like to briefly highlight a number of changes to the Tax Code of the Russian Federation covering the main amendments involving the taxation of individuals which were introduced by Federal Law No. 425-FZ of 28 November 2025, as well as changes related to determining the revenue of organisations that take advantage of the simplified taxation system adopted by Federal Law No. 70-FZ of 23 March 2026 in pursuance of Resolution of the Constitutional Court of the Russian Federation No. 2-P of 21 January 2025.

Constitutional court ruling on compulsory licences

The Constitutional Court has regulated the application of the “compulsory licensing” mechanism to combat right holders maintaining “unreasonably high” prices for pharmaceuticals, with the caveat that this is a necessary measure to protect consumers from the abuse of intellectual property rights by bad faith persons.

Supreme court’s position on the burden of proof and the use of Internet sources in customs value adjustments

In this legal update, we would like to draw your attention to a new, important ruling of the Judicial Collegium on Economic Disputes of the Supreme Court of the Russian Federation dated 26 February 2026, in case No. A51-4600/2024. This ruling is significant for two key findings.

Distribution of participation interest of former participant among remaining participants is recognised as income for personal income tax purposes

In February 2026, the court adopted a precedent-setting decision in the case of Signal-Invest LLC . Under this decision, for the first time the issue concerning the tax consequences of the gratuitous distribution of participation interest redeemed by the company upon the withdrawal of one participant among the remaining participants was considered.

State Duma adopts amendments to legislation on strategic investments

On 26 February 2026, the State Duma adopted in its third and final reading a federal law (Draft Law No. 1082676-8) amending Law No. 57-FZ and certain other legislative acts, aimed at expanding the grounds for approving transactions concluded by foreign investors with respect to strategic companies and bringing the rules on strategic investments into compliance with the established law enforcement practice.

Misuse of budgetary funds by concessionaires: court vs “flexibility” of PPPs

Public-private partnerships have long been positioned as a mechanism that provides businesses with a certain degree of freedom in implementing infrastructure projects, in contrast to the rigid framework of government contracts. However, judicial practice in 2024-25 demonstrates an inexorable trend: an approach is emerging aimed at preventing the misuse of funds and minimising the risk of damage to public entities.

Extending the special procedure for calculating withholding tax in relation to certain payments to “unfriendly” counterparties

Further to our series of publications on changes to tax law, we would like to bring to your attention the following important provisions of Federal Law No. 425-FZ dated 28 November 2025.

Review of UK sanctions of 24 February 2026

On 24 February 2026, the United Kingdom announced new blocking sanctions targeting several hundred Russian and foreign entities, as well as ships transporting Russian oil and gas.

Changes to the Tax Code of the Russian Federation in 2026 (Part 2)

We continue our series of publications with an overview on key changes to the Tax Code of the Russian Federation. In today's overview, we will briefly examine innovations in the taxation of legal entities.

On tax consequences of the expropriation of property from owners for state (municipal) needs

As part of the large-scale amendments adopted to tax legislation at the end of 2025, in order to eliminate tax uncertainty, legislators adopted amendments to the Tax Code of the Russian Federation clarifying the procedure for the VAT and corporate income taxation of the reimbursement (compensation) received by former owners for the expropriation of immovable property from them for state (municipal) needs.

Insights

Insights