The Tax Code of Russia establishes rules on controlled foreign companies (Article 25.13 of the Tax Code of the Russian Federation).
If an organization or individual is a resident of the Russian Federation:
have an interest in a foreign organization
or
exercise control over a foreign organization,
– then such residents of the Russian Federation are required to annually submit a CFC notice to the tax authorities.
Notification is submitted by:
organizations – until March 20
individuals – until April 30.
For example, in 2022, notifications were submitted for the 2021 tax period in respect of a CFC fiscal year that ended in 2020:
Fiscal year of the CFC
Tax period in which the CFC recognizes income from profit
Year of notification in the Russian Federation
2020
2021
2022
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The tax authority requires that the financial statements of the foreign organization, as well as an auditor’s report, be attached to the notification of a CFC.
The fine for failure to submit these documents is 500,000 rubles (clause 1.1. Article 126 of the Tax Code of the Russian Federation).
The audit of CFC financial statements can be carried out by Russian auditors who have been applying the International Auditing Standards since 2017, which reduces the cost of attracting foreign auditors.
Of course, the auditor must be able to audit reports prepared in accordance with International Standards on Auditing.
have an interest in a foreign organization 
