The Federal Tax Service has prepared a draft document "On approval of the List of states (territories) that allow systematic failure to fulfill obligations for the automatic exchange of country reports." The draft list contains 21 jurisdictions. Among the countries are Austria, Germany, Belgium, France, Italy, Spain, Luxembourg, the Netherlands, Greece, Ireland, Japan, Australia, Cyprus and other countries.
Russia carries out automatic exchange of financial information with several countries. The list of these countries and territories is fixed by Order of the Federal Tax Service of Russia dated October 28, 2022 N ED-7−17/986@ On approval of the List of states with which automatic exchange of financial information is carried out. In practice, over the past two years, the Federal Tax Service of Russia has faced a data transfer problem because some countries do not fulfill their obligations to exchange country reports with the Russian Federation automatically. Therefore, the project provides for a "blacklist" of countries that systematically commit violations.
Russian subsidiaries of international groups of companies will be required to submit country reports to Russian tax authorities in accordance with the format established in the Russian Federation if the company of their group responsible for filing such a report is located in a country from the approved list. Russian subsidiaries are exempt from preparing and filing country reports under Russian rules if the jurisdiction where the headquarters or authorized participant of an international group of companies is located automatically exchanges country reports filed abroad with the Russian tax authorities.
Russian subsidiaries of international groups of companies will be required to submit country reports to Russian tax authorities in accordance with the format established in the Russian Federation if the company of their group responsible for filing such a report is located in a country from the approved list. Russian subsidiaries are exempt from preparing and filing country reports under Russian rules if the jurisdiction where the headquarters or authorized participant of an international group of companies is located automatically exchanges country reports filed abroad with the Russian tax authorities.
The introduction of a "blacklist" will affect transfer pricing reporting.
In particular, Russian companies that are part of an international group of companies whose parent company is registered in a country from the "blacklist" will need to provide a country report at the request of the Federal Tax Service because There will be no automatic exchange of financial information across these countries.
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