The Federal Tax Service will explain to companies the rules of tax amnesty for corporate fragmentation

The decision of the department was preceded by a thematic meeting held behind closed doors about a month ago together with the business association “Opora Rossii” and companies from 40 regions of Russia.

Entrepreneurs have questions about new terms that appeared in the Tax Code (TC) in July, including “business fragmentation”, “voluntary refusal to fragment” and “control over the same persons” (companies and sole proprietors). One of the signs of fragmentation is the division of a single business activity between formally independent persons. The main goal is to reduce taxes.

The companies asked the Federal Tax Service to clarify the clear algorithm for paying taxes in case of voluntary refusal of fragmentation, the specifics of applying a partial amnesty, the prohibition of transferring inspection materials for such a crime to the investigating authorities, as well as cases that the Federal Tax Service will not classify as fragmentation, an Opora representative told Vedomosti Russia.

• The amnesty will apply to those entrepreneurs who consolidate their business and move to a common tax system from 2025 onwards.

• Those who are amnestied will be exempt from paying taxes, penalties and fines for the period 2022-2024 if the tax authorities, based on the results of audits in 2025 and later, do not find any violations.

• Companies in respect of which inspections have already been initiated and decisions have been made, but have not entered into force, on the need to merge a chain of organizations or individual entrepreneurs into a single company will also not have to pay. Decisions of the Federal Tax Service that entered into force only in 2025 will not be canceled.