The list of income related to the income of a foreign company from sources in Russia and subject to taxation has been expanded

From January 1, 2024, a 15% withholding tax will be introduced on income paid to foreign affiliated parties for the performance of work and provision of services.
Article 309 of the Russian Tax Code has been supplemented with a new clause, which includes income received by a foreign organization from performing work (rendering services) in Russia to related parties determined by Article 105.1 of the Tax Code of the Russian Federation.

The work is considered completed (services are considered provided) on the territory of Russia if the buyer of the work (services) carries out activities on the territory of the Russian Federation.

Thus, if a Russian company in 2024 pays for any services of a foreign company from the same group and which is affiliated, then the Russian company will have to withhold 15% tax at source.