The Federal Tax Service tightened control over cross-border payments through foreign agents

The tax authorities have increased oversight of international settlements involving foreign intermediaries. Russian companies have begun to receive massive demands for additional withholding tax on payments to non-residents for agency services, experts say.

The essence of the problem:

• The Federal Tax Service requires withholding tax at a rate of 15% on remuneration to foreign payment agents, procurement intermediaries and logistics operators

• The focus is on importing companies and logistics operators

• The tax service actively requests registers of payments, business models of counterparties and information about beneficiaries

Legal justification:

The requirements are based on Federal Law No. 539, which obliges Russian companies to withhold tax at the source of payment if the recipient of income is a non-resident and the parties are recognized as interdependent.

Practical examples:

A major Russian bank reports that its clients have received notifications about the need to pay taxes on the profits of non-resident companies. Similar requests are recorded in various sectors of the economy.

Expert assessment:

Experts note that the Federal Tax Service is systematizing its approach to taxation of cross-border transactions. Companies need to audit their international contracts and ensure that tax rates are applied correctly.

This situation requires increased attention to documenting transactions with foreign counterparties and analyzing their tax consequences in order to avoid the imposition of sanctions by the tax authorities.