Article 126 of the Penal Code of the Russian Federation of draft law No. 84984-8 will be supplemented with point 4 on the abolition of liability for failure to submit documents on the amount of profit (loss) of a controlled foreign company for the financial years 2020 and 2021. This means that the penalties of RUB 500,000 and RUB 1,000,000 will be removed.

In addition the same draft law also amends Article 105 of the Penal Code of the Russian Federation, according to which the threshold for controllable cross-border transfer pricing transactions is to be increased from 60 million roubles to 120 million roubles. Therefore foreign trade transactions, can only be controlled by the tax authorities if the turnover of the legal transaction exceeds EUR 120 million. In addition, during the period from 1 January 2022 to 31 December 2024, Article 105.14 of the Penal Code of the Federation, which provides that a legal transaction is deemed to be controllable if one of the contracting parties claims exemption from investment tax on profits, will not be applied.

Finally the same draft law, by amending Article 217 of Penal Code of the Russian Federation, establishes that certain types of income will be exempt from income tax.