New special list of offshore countries for 2024-2026

In accordance with Article 4 of Federal Law No. 595-FZ from December 19, 2023, on April 27, 2024, the Ministry of Finance approved a new special list of states and territories that provide preferential tax treatment and (or) do not provide for disclosure and provision of information in financial transactions (offshore zones).

The effect of the Order of the Ministry of Finance (Order of March 28, 2024, No. 35n) extended to relations arising from January 1, 2024 and it should be applied to tax periods from 2024 to 2026.

The new list includes only 40 countries and is almost 2 times less than the one approved by the Ministry of Finance in June 2023. Thus, all countries of the European Union, Australia, Canada, the Republic of Cyprus, the United Kingdom and Northern Ireland, the United States, Taiwan (China), Ukraine and Japan have been excluded from the List.

The new List should be applied:

  • for exemption from taxation of profit of controlled foreign companies (CFCs) under paragraph 3, item 7, article 25.13-1 of the Tax Code of the Russian Federation;

  • for the adjustment of CFC profits under subparagraph 3, paragraph 1.2, Art. 25.13-1 of the Russian Tax Code;

  • for determining the tax base for profits tax under par. 3 of par. 11 item 1 Art. 251 of the Tax Code of the Russian Federation;

  • for the application of the profit tax rate under subpar. 1 or 1.1 of par. 3 of Article 284 of the Russian Tax Code.