02.06.2025
Rules established by Pillar Two will apply in Russia from 2026
Starting from 2021, the Organization for Economic Cooperation and Development (OECD) released Model Global Anti-Base Erosion (GloBE) rules under Pillar Two.
Model Rules set approach for a Global Minimum Tax at 15% for multinational enterprises (MNE) with a group turnover of more than EUR 750 million. The European Union (EU) and some other OECD countries introduced Pillar Two from 2024 in the national legislation. Currently Russia has prepared the draft law, under which the minimum profit tax at the rate of 15% will apply for MNE, starting from 2026.
Under the new draft law, if the effective profit tax of Russian subsidiaries of MNE is less than 15%, the extra tax should be paid up to 15% rate to the Russian budget. New rules could apply for Russian companies that use different tax benefits. Calculation of effective tax rate should be performed separately by each Russian company of MNE (meanwhile under the Model Rules the effective tax rate is to be calculated for all local companies within one jurisdiction).
Tax at the rate of 15% will be divided into 5% paid to federal budget and 10% paid to regional budget of Russia.
It should be noted that the details of the draft law will be discussed further and now it is necessary to monitor the changes and the process of enactment of the draft law.