Russia has introduced special corporate income tax calculation rules for certain Russian members of multinational enterprise (MNE) groups, including a 15% rate where specified conditions are met.
Russia has introduced special rules for calculating corporate income tax for members of international groups of companies, with the clarifications published by the Federal Tax Service (FTS) in Tax Policy and Practice, No. 8/2026, on 18 August 2026.
The rules apply from 2026 to members of international groups of companies, except for foreign organisations that do not conduct activities in the Russian Federation through a permanent establishment.
The following conditions must be met simultaneously:
- As of 31 December of the relevant tax period for which the tax base is determined for the purposes of Article 288.5 of the Tax Code of the Russian Federation, the parent company of the MNE group must be a tax resident of a foreign state;
- As of the same date, the parent company or an intermediate holding company of the MNE group must be a resident of a country that has introduced a global minimum level of taxation (GloBE) in accordance with the OECD Model Rules (Pillar Two);
- The consolidated income (revenue) of the MNE group must exceed or may exceed the threshold of EUR 750 million for each of the two years preceding the tax period for which the tax base is determined for the purposes of Article 288.5 of the Tax Code of the Russian Federation; and
- The tax burden ratio calculated by the Russian member of the MNE group must be positive and less than 0.15.
15% corporate income tax rate
An MNE group member that meets these conditions calculates corporate income tax at a rate of 15% for the tax period. This comprises 5% payable to the federal budget and 10% payable to the budgets of the constituent entities of the Russian Federation, instead of the rate normally applied.
The tax base is also calculated under special rules in this case.
The specified procedure does not apply to income from participation in other organisations. Tax on such income is paid under the usual rules set out in paragraph 1.1 of Article 274, paragraph 1.20 of Article 284 and paragraph 4 of Article 288.5 of the Tax Code of the Russian Federation.
