Key changes in the tax system:

The recent set of amendments to tax regulations has become one of the most far-reaching in recent years. The updates affect virtually all categories of taxpayers, from micro-businesses to international corporate groups. Below, we’ve summarized the key changes and practical implications that should be considered today in operational activities, compliance, and strategic planning.

1. Lowering the threshold for special tax regimes

The transition to preferential regimes will become available to a smaller number of companies: the maximum annual revenue will be reduced in stages.

Main changes:

• reduction of the income limit for the use of preferential regimes;
• a transition period allowing businesses to adapt;
• the emergence of an open list of expenses that can be taken into account when calculating the tax on “income minus expenses”;
• tightening the requirements for combining simplified regimes with the payment of turnover tax at the new rate.

What this means for businesses:
Companies on the brink of profitability may face an increased tax burden. At the same time, an open list of expenses reduces administrative barriers and allows for a more accurate accounting of actual costs. It would be advisable for businesses to evaluate their financial model in advance, taking into account the combined burden.

2. Increasing the indirect tax rate

As part of the reform, the basic indirect tax rate has been increased, which will affect all participants in economic activity.

Key points:

• increase in the general rate for all taxpayers;
• maintaining a simplified compensation mechanism for large companies during the transition period;
• special consequences for the SME segment, where the preferential rate without the right to deduct is more often used.

Consequences:
For large companies, the impact is primarily limited to an increase in the rate. For small businesses, the cost of goods and services may increase more significantly due to the lack of a deduction mechanism. Companies working under long-term contracts should reconsider their payment terms.

3. Expansion of control powers of tax authorities

Tax control procedures have become more formalized and deeply integrated into the operational activities of companies.

New control tools:

• expansion of on-site analysis capabilities;
• the right to conduct inspections and seizures as part of the review of inspection materials;
• collection of evidence after receiving taxpayer objections.

How will this impact companies?
The risks of unpredictability during audits are increasing. The review stage becomes an extension of the audit itself, requiring companies to create “protective files” in advance and standardize internal document flow.

4. Extraterritorial tax audits

A principle has been introduced whereby reports can be analyzed by any authorized inspectorate, regardless of the company’s region.

Key Features:

• uniform control standards throughout the country;
• the disappearance of the “human factor” and personal communications;
• remote interaction format and strict formality of procedures.

Conclusions for businesses:
On the one hand, the methodology becomes more predictable. On the other, the likelihood of formal inquiries and additional assessments increases. Appeals procedures also become extraterritorial, but a court appeal at the taxpayer’s location facilitates the protection of interests.

5. New rules for reducing tax penalties

The reduction of penalties is now limited and has become strictly regulated.

Changes include:

• limiting the maximum reduction of the fine to ten times the limit;
• a uniform calculation method using a simple formula;
• reducing the number of mitigating factors that can be taken into account.

Practical effect:
Companies are deprived of the opportunity to significantly reduce sanctions, which increases the requirements for tax discipline and internal control.

6. Introduction of minimum corporate taxation (similar to Pillar 2)

A special mechanism is being introduced for international groups to ensure a minimal level of tax burden.

Main content:

• commitment to maintain the effective corporate tax rate at a specified level;
• calculation for each legal entity of the group separately;
• potential differences in calculation methods between countries.

Why this is important:
This creates significant administrative requirements and increases the risk of double taxation. Companies in international groups should prepare calculations in advance and analyze potential discrepancies in the approaches of different jurisdictions.

7. Expanding control over transactions with low-tax jurisdictions

Transfer pricing rules now cover transactions not only with offshore territories, but also with jurisdictions with reduced tax rates.

Key innovations:

• the emergence of a new control criterion – a low corporate tax rate in the counterparty’s country;
• the need to confirm the level of taxation if the jurisdiction has different rates or a progressive scale;
• potential complication of compliance.

Impact on business:
Companies will need to expand the scope of data they collect and become more willing to justify market terms of transactions.

8. “Technology levy” on electronic products

Starting in 2026, a new mandatory payment will be introduced for the import of electronic components and products based on them.

Main elements:

• fixed rate of duty per unit of goods;
• regulation of specific parameters and lists will be determined later;
• payment obligation for importers and manufacturers using foreign components.

Electronics and distribution businesses should monitor upcoming regulations, as they will determine the actual burden.

9. Changes for the IT industry

Despite expectations of tightening, a number of key benefits for IT companies were retained.

Saved and updated measures:

• maintaining a preferential indirect tax rate for the sale of software from the national register;
• increasing the preferential rate of insurance premiums for accredited companies;
• changes in conditions for individual innovation clusters, including those affecting preferential mortgage support programs.

Result:
The IT sector retains its basic benefits, but the personnel and financial burden is expected to increase due to higher contribution rates.

10. Benefits under international tax treaties

Some provisions of the suspended agreements were extended, but not in full.

Key points:

• partial extension of certain benefits;
• reduction of the list of incomes exempt from taxation;
• the introduction of a new, highly specialized benefit related to the forgiveness of debt of foreign organizations.

Impact Assessment:
It is important for corporations with international ownership structures to proactively model tax implications and update contracts to account for potential increased burdens.

11. Maintaining the usual tax payment deadlines

Initially, it was proposed to change the rules for calculating deadlines if they fall on a weekend or holiday, but these changes were not included in the final version.

It means:

• maintaining a clear and established order;
• reducing the risk of new disputes and uncertainties;
• compliance stability.