The country report is submitted by the parent company of the IGC or an authorized participant of the IGC if they are Russian organizations or foreign organizations (structures without a legal entity) that have voluntarily recognized themselves as tax residents of the Russian Federation. The report must be provided not later than 12 months from the end of the reporting period. Furthermore, the country report should be submitted at the request of the Tax Authorities. This rule isn’t applied to participants of the IGC — foreign organizations that receive only the income specified in article 309 of the Tax Code.
There is a list of conditions under which, at the request of the Federal Tax Service, the country report may not be submitted by the IGC participant in respect of whom a notification of participation in the IGC was submitted (or the participant submitted such a notification itself).In fact, it turns out that the country report is submitted by the Russian participant of IGC, where the parent company or authorized participants are tax residents of foreign States, in the following cases:
- the state is included in the list of countries systematically not acting in the exchange of country reports;
- the Federal Tax Service has information that the country report was not submitted abroad.