Taxation of transactions with foreign payment intermediaries in 2025: peculiarities and nuances

In 2025, Russian companies should take into account several key aspects of taxation related to work with foreign payment agents.

1. VAT (item 5, Clause 1 of Article 148 of the Tax Code of the Russian Federation):

   – The services of foreign agents to transfer funds are not subject to VAT in Russia. This means that in settlements with a payment agent a Russian company should not charge VAT on the commission amount.

   – The place of sale of services is determined at the location of the contractor.

   – Notifications to the tax authority on such transactions are not required, which simplifies reporting for Russian companies.

2. Profit tax (Clauses 1 and 2 of Article 309 and Clause 4 of Article 310 of the Tax Code of the Russian Federation):

   – Income of a foreign agent is not subject to profit tax in Russia, provided there is no interdependence between the Russian organization and the agent.

   – It is important to note that it is required to submit a Tax Settlement to the tax authority. The form of the calculation was approved by Order of the Federal Tax Service No. ED-7-3/675 dated 26.09.2023.

   – The key conditions for exemption from profits tax are absence of interdependence between the organization and the agent, absence of permanent establishment of the agent in Russia, and recognition of income as a source in Russia.

Accounting for commission for payment agent services

A Russian company using the services of a foreign payment agent has the right to account for the commission paid for the transfer of funds in its accounting and tax records.

1. Accounting:

   – The commission paid to a foreign payment agent should be recognised as an expense in the accounting records. This can be done through account 91 ‘Other Income and Expenses’ or through account 26 ‘General and Administrative Expenses’, depending on the company’s accounting policy.

   – It is important to document the fact of rendering services and the amount of commission, which can be done on the basis of the contract with the payment agent and the invoice.

2. Tax accounting:

   – In tax accounting, the commission is also subject to accounting as an expense that reduces the taxable base for income tax. However, care should be taken to ensure that the expenses are economically justified and documented.

   – If the commission exceeds the established limit or has signs of misuse, the tax authorities may challenge such expenses.