Procedure for Applying Amnesty in Business Splitting

FBK Legal’s team has reviewed an application of tax amnesty for business splitting, in accordance with a letter from the Federal Tax Service of Russia. Back in 2024, a law² was adopted introducing tax amnesty for businesses that abandon splitting. If a taxpayer voluntarily renounces business splitting starting 1 January 2025, the amnesty will apply to the three preceding tax periods. However, the amnesty can only be applied for 2022 and 2023 if the renunciation of business splitting in 2025 or 2026 occurs after the initiation of an on-site tax audit. The law did not specify the methods for renouncing business splitting. As a result, the FTS of Russia issued a letter³ outlining potential approaches. For more details, read our full review via the link.