On 6 May 2018, Russia’s Federal Tax Services (FTS) issued Order No. MMV-7-17/123 and Order No. MMV-7-17/124 issued on 26 April 2018 in the Official Gazette. The orders approves the format and method of submission for Country-by-Country (CbC) reports and related Notifications, as well as instructions for completing and filing these forms electronically.

The Orders require that the CbC report and the notification be electronically submitted in XML format and signed by a qualified electronic signature. They also contain the information requirements as well as the instructions and technical requirements for the XML files. The XML schemas are to be provided on the official website of the Federal Tax Service. According to the order, the CbC report and the CbCR Notification must be prepared in Russian, but it is also permitted to provide the information in a foreign language.

The CbC report should be submitted for financial years starting in 2017, no later than 12 months after the end of a financial year. The CbC report may be submitted on a voluntary basis for financial years starting in 2016.

Under Russian law, taxpayers who are part of a multinational group must submit a CbCR notification to the multinational group at least eight months after the end of the financial year. The legislation also permits a single notification to all members of a multinational group who are taxpayers in the Russian Federation.

In general, all CbCR forms comply with the requirements of Action 13 of the Organization for Economic Co-operation and Development of Basic Erosion and Profit Shifting (BEPS). Although additional information regarding employee and capital reporting is included. For employees, a distinction is made between the number of employees under employment contracts, the number of employees in civil law contracts and the total number of employees. In relation to the capital, there is a position for “additional capital”, which is the equity less the amount of the reported capital and the accrued income. The additional civil contracts for employees and the additional capital are optional.