FEDERAL LAW OF THE RUSSIAN FEDERATION

of December 19, 2023 No. 595-FZ

About modification of parts the first and second Tax Code of the Russian Federation and article 9 of the Federal law "About Modification of Parts the First and Second Tax Code of the Russian Federation and Separate Legal Acts of the Russian Federation"

Accepted by the State Duma on December 7, 2023

Approved by the Federation Council on December 13, 2023

Article 1

Bring in part one of the Tax Code of the Russian Federation (The Russian Federation Code, 1998, No. 31, Art. 3824; 1999, No. 28, Art. 3487; 2004, No. 27, Art. 2711; 2006, No. 31, Art. 3436; 2010, No. 31, Art. 4198; 2011, No. 30, Art. 4575; No. 47, Art. 6611; No. 49, Art. 7014; 2013, No. 40, Art. 5037, 5038; No. 52, Art. 6985; 2014, No. 14, Art. 1544; No. 48, Art. 6657, 6660; 2015, No. 24, Art. 3377; 2016, No. 7, Art. 920; No. 22, Art. 3092; No. 27, Art. 4176; No. 49, Art. 6844; 2017, No. 1, Art. 16; No. 49, Art. 7307; 2018, No. 1, Art. 20; No. 9, Art. 1291; No. 30, Art. 4534; No. 31, Art. 4821; No. 32, Art. 5087, 5095; No. 45, Art. 6828; No. 49, Art. 7496; No. 53, Art. 8416; 2019, No. 23, Art. 2908; No. 39, Art. 5374, 5375; 2020, No. 46, Art. 7212; 2021, No. 8, Art. 1196; No. 24, Art. 4217; No. 27, Art. 5133; No. 49, Art. 8143; 2022, No. 9, Art. 1250; No. 13, Art. 1955, 1956; No. 18, Art. 3006; No. 29, Art. 5230; 2023, No. 1, Art. 12; No. 16, Art. 2762; No. 32, Art. 6121, 6147; No. 49, Art. 8656) following changes:

In paragraph one of Item 1.1 of Article 21 of the word of "government" to exclude 1);

2) in Article 24.2:

a) in Item 1:

in paragraph five of subitem 2 of the word "December 31, 2022" shall be replaced with words "on December 31, 2023";

add subitem 3 with the paragraph of the following content:

"Provisions of this subitem are not applied to the international company registered according to the procedure of redomitsilyation till March 1, 2022 (inclusive).";

b) in Item 1.1:

in paragraph three of subitem 2 of the word of "government" to exclude;

in subitem 3 of the word of "government" to exclude;

c) in Item 1.2:

in paragraph one of the word "No later than" shall be replaced with words "If other is not provided by this Item, not later", to exclude words of "government";

in the paragraph the second to exclude words of "government", the words "more than one percent" shall be replaced with words "more than 1 percent (for the federal cities of Moscow, St. Petersburg and Sevastopol - more 0,1 of percent)";

add with the paragraph of the following content:

"The organization specified in Item 1.1 of this Article at which for each of three calendar years preceding calendar year in which such organization makes the decision on change of the place of its stay on the territory of the special administrative area, share of receipts from payment of the income tax of the organizations by such organization in the total amount of the income from receipt of the income tax of the organizations of the budget of the subject of the Russian Federation, in the territory of which is located the organization location before its change on the territory of the special administrative area (was located) constitutes less than 1 percent (for the federal cities of Moscow, St. Petersburg and Sevastopol - less 0,1 of percent) having the right to direct the notification specified in paragraph one of this Item in the supreme executive body of this subject of the Russian Federation not later than one month before date of filing of application about acquisition of the status of the international holding company.";

In paragraph three of Item 7 of Article 25.13-1 the word "Profit" shall be replaced with words 3) "If other is not stipulated by the legislation about taxes and fees, profit", the words "the list of the states (territories) approved by the Ministry of Finance of the Russian Federation according to the subitem 1 of Item 3 of Article 284 of this Code" shall be replaced with words "the list of the states and the territories which are providing preferential tax regime of the taxation and (or) not providing disclosure and provision of information when carrying out financial transactions (offshore zones) approved by the Ministry of Finance of the Russian Federation";

Article 25.14 to add 4) with Item 13 of the following content:

"13. The taxpayer recognized according to Item 3.1 of Article 25.13 of this Code the controlling person of the foreign organization according to the procedure of which redomitsilyation the international company is registered is exempted from liability, stipulated in Article 129.6 of this Code for non-presentation of the notification on the controlled foreign companies if such foreign organization according to its personal law is recognized actually stopped the activities (the invalid legal entity).

For application of provisions of this Item the taxpayer submits the documents confirming recognition of the foreign organization specified in paragraph one of this Item according to its personal law actually stopped the activities (the invalid legal entity). Such documents are submitted in time, stipulated in Item 2 these Articles, and are subject to transfer into Russian in the part necessary for confirmation of observance of condition of application of provisions of this Item.";

5) in Article 25.15:

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