Starting from 28 March 2022, based on the amendment of paragraph 3.2 of art. 23 of the Tax Code of the Russian Federation implemented by Federal Law No. 100-FZ of 20 April 2021, for the first time foreign companies will have to provide information on the beneficiaries of representative offices, branches of foreign companies and permanent representative offices of foreign companies.

A declaration on participants, beneficiaries, founders and directors as at 31.12.2021 must be submitted by 28 March 2022 to the Federal Tax Service at the place of tax registration. The information provided should cover all direct participants as well as indirect participants (individuals or public companies) if their shareholding exceeds 5%.

From the point of view of companies, the minimum threshold of 5% for dissemination of information is rather low. This obliges them to collect a lot of information on final beneficiaries and intermediate owners. However not all foreign companies have data on the chain of ownership, in particular the personal data of individual beneficiaries. Non-submission or late submission of information may result in a fine of 50,000 roubles under clause 2.1 of Article 129.1 of the Tax Code of the Russian Federation.