April changes for businesses: new conditions for tax benefits, accelerated disclosure of Federal Tax Service data, and regulation of installment services

A set of changes will come into effect in April, affecting the application of tax incentives, the disclosure of tax information, the regulation of installment services, certain aspects of cross-border transfers, and payment infrastructure. The overall focus of the changes is to transition from formal status as a participant in a special regime or financial service to regular confirmation of compliance with established criteria, indicators, and reporting requirements.

The changes are most significant for new investment projects, companies using special tax regimes, digital financial service operators, and organizations for which the assessment of their business reputation by banks and counterparties is critical.

New conditions for applying benefits for residents of special regimes

As of April 1, new residents of priority development areas, free ports, Arctic zones, special economic zones, and other special regimes will be required to confirm their eligibility for tax benefits.

Resident status alone is no longer considered an absolute basis for applying preferential treatment. Eligibility for preferential treatment must be confirmed annually based on a set of mandatory criteria.

These criteria include:

• fulfillment of investment obligations;
• compliance with KPIs stipulated by the agreement or investment declaration;
• absence of systematic violations of reporting discipline;
• maintaining the established relationship between investment and tax savings.

The key element is the investment indicator, which requires that the volume of capital investments and individual expenses, including R&D, be proportionate to the amount of tax benefit received. If the established ratio falls below the permissible value, the right to apply the benefits is lost for the next tax period.

Thus, the benefit takes on the character of a conditional support measure, directly linked to the actual implementation of the project’s investment model.

Strengthening the importance of regional regulation

A significant portion of the new model’s parameters has been delegated to the constituent entities of the Russian Federation. Regions are now empowered to determine:

• specific project KPIs;
• permissible deviations from the indicators;
• investment ratio coefficients;
• rules for indexation of capital investments;
• certain features of accounting for R&D expenses.

This may lead to differences in law enforcement practices depending on the project’s location. Therefore, the importance of regional regulation when launching new investment initiatives increases significantly.

Particular attention will need to be paid to the structure of project companies, since new legal entities created within the framework of existing investment programs will be subject to the updated procedure.

Accelerated disclosure of data by the Federal Tax Service

Starting in April, the deadlines for publishing open taxpayer data will change. Information on tax liabilities and arrears will become available more quickly and will be updated more frequently than before.

In practice, this means that external users will have quicker access to information about:

• the presence of tax arrears;
• overdue insurance premiums;
• technical delays in the distribution of the single tax payment;
• temporary cash flow gaps;
• unsettled charges.

This information acquires independent significance for assessing an organization’s business reliability. More frequent disclosure of information increases the impact of tax discipline on financing terms, transaction limits, advance payment approval procedures, and other commercial interaction parameters.

As a result, meeting tax deadlines takes on not only fiscal but also reputational significance.

Separate regulation of installment services

Starting April 1, special regulations will be introduced for the activities of installment payment service operators operating through digital platforms and information systems.

Only organizations included in a special registry will be able to carry out such activities. Requirements for admission to work include:

• minimum capital amount;
• corporate governance;
• structure of participants;
• disclosure of the rules of the service;
• transfer of information to credit bureaus.

At the same time, direct restrictions are being introduced on the funding and monetization model of such services.

In particular, the operator is prohibited from:

• attract funds from individuals;
• charge a separate fee for providing an installment plan.

These requirements require additional legal and financial assessment of existing digital sales models in which installment payments are integrated into the ordering process.

Extension of restrictions on transfers by non-residents

For the next period, restrictions on the transfer of funds abroad by non-residents from certain jurisdictions placed in the accounts of Russian brokers and trust managers remain in place.

Given the duration of such measures, they have effectively become a permanent element of the financial infrastructure and are taken into account when structuring settlements, managing liquidity, and planning asset flows.

When constructing calculation models, the following must be taken into account:

• restrictions on the withdrawal of funds outside the Russian infrastructure;
• Features of using special accounts;
• localization of assets within the national financial system;
• restrictions on cross-border redistribution of liquidity.

Changes in the payment infrastructure

Additionally, the ability to make transfers through the Fast Payment System is being expanded for branches of foreign banks that are direct participants in the Bank of Russia payment system.

From a practical perspective, this expands the internal settlement capabilities of such banks’ clients within the Russian payment infrastructure and partially reduces dependence on traditional international funds transfer channels.

Practical significance of the changes

The changes under consideration are united by a common regulatory logic: the provision of benefits, access to certain types of financial services, and the assessment of market participant reliability increasingly depend on regular confirmation of established indicators, transparent reporting, and compliance with the discipline of fulfilling obligations.

In the current circumstances, the following acquire priority:

• separate accounting of investments and tax savings;
• control of KPIs under investment agreements;
• monitoring the deadlines for fulfilling tax obligations;
• checking the compliance of digital services with new requirements;
• adaptation of calculation models to current restrictions.

These measures ensure compliance with new requirements and reduce legal, financial and reputational risks associated with regulatory changes.