Tax Authorities Interested in Foreign Debts Frozen Due to Sanctions
According to RBC, the Federal Tax Service (FTS) has turned its attention to receivables of Russian entities that have become frozen due to sanctions. What additional taxes may be assessed against companies due to the presence of unrecoverable foreign debts, and what arguments are being used in this context. Tax attorneys and consultants told RBC that the authorities have begun requesting information from businesses regarding their receivables (amounts due from counterparties) with expired limitation periods. A mass rollout of such requests is claimed to have begun in the summer of 2026. Experts note that the FTS now views overdue receivables not merely as an accounting issue, but as a potential red flag that economic benefits are being removed from the tax base.
The FTS of Russia confirmed to RBC that, within the scope of its authority, it analyses on a regular basis transactions between residents and foreign counterparties, including matters related to accounts receivable. "Where grounds exist under tax and currency legislation, such analysis may be accompanied by requests for documents and information," the authority clarified.
Alexei Nesterenko, Managing Partner at FBK Legal on the ways to mitigate risks:
Overdue receivables do not themselves constitute a violation — what matters most is the rationale behind business transactions and measures taken by the company to recover the outstanding amounts.
As for advance payments, including those made to foreign counterparties, their economic viability must be documented. For example, prepayment may be justified by securing substantial discounts, guaranteeing the supply of goods that are difficult to obtain in the current geopolitical environment, or by special cooperation terms. Furthermore, if advance payments have not been refunded, it is critically important to document all measures taken to recover the funds — including formal claims, litigation filings, and correspondence with the counterparty.
