Overview of Key Tax Developments in the Fourth Quarter of 2025
This overview summarises the principal tax developments in the fourth quarter of 2025 that are relevant to businesses.
Legislative Developments
- On 28 November 2025, the President signed a law adopted as part of the implementation of the main directions of tax policy¹.
- Criteria for assessing taxpayers have been approved.
- The Ministry of Finance has introduced rules governing the exchange of data between digital platform operators and the tax authorities.
Case Law
- The Constitutional Court restricted the ability to pass VAT on to a purchaser deprived of the right to deduction where transactions under an ongoing contract become subject to VAT.
- For the first time, the courts considered a case involving the application of the Multilateral Instrument (MLI) (the Khimtech LLC case).
- The Judicial Chamber for Economic Disputes of the Supreme Court of the Russian Federation held that a tax agent is required to provide documents at the request of the tax inspectorate in the course of a desk audit.
- The Supreme Court of the Russian Federation upheld the tax authority in a dispute concerning the accounting treatment of funds in the Unified Tax Account.
Guidance from the Ministry of Finance and the Federal Tax Service
- The Federal Tax Service clarified the tax treatment of income arising from disproportionate profit distribution.
- Key guidance on the new mechanism for out-of-court recovery has been published.
- The Federal Tax Service clarified the procedure for transitioning from the 20% VAT rate to the 22% VAT rate.
International Taxation
- A revised list of jurisdictions participating in the automatic exchange of information has entered into force.
- A revised list of jurisdictions participating in the automatic exchange of country-by-country reports has entered into force.
- The United Arab Emirates has been removed from the list of offshore jurisdictions.
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