FEDERAL LAW OF THE RUSSIAN FEDERATION

of July 23, 2025 No. 227-FZ

About modification of part the second Tax Code of the Russian Federation

Accepted by the State Duma on July 10, 2025

Approved by the Federation Council on July 16, 2025

Article 1

Bring in part the second the Tax Code of the Russian Federation (The Russian Federation Code, 2000, No. 32, the Art. 3340, 3341; 2001, No. 1, Art. 18; No. 23, Art. 2289; No. 33, Art. 3413; No. 53, Art. 5015, 5023; 2002, No. 22, Art. 2026; No. 30, Art. 3021, 3027; 2003, No. 1, Art. 2, 5, 6; No. 21, Art. 1958; No. 28, Art. 2886; No. 46, Art. 4443; No. 52, Art. 5030; 2004, No. 27, Art. 2711, 2715; No. 31, Art. 3231; No. 34, Art. 3517, 3518, 3520, 3524; No. 35, Art. 3607; No. 45, Art. 4377; 2005, No. 1, Art. 30, 38; No. 24, Art. 2312; No. 27, Art. 2707, 2710, 2717; No. 30, Art. 3101, 3104, 3112, 3128, 3129, 3130; No. 52, Art. 5581; 2006, No. 10, Art. 1065; No. 12, Art. 1233; No. 31, Art. 3436, 3443, 3452; No. 45, Art. 4627, 4628; No. 50, Art. 5279, 5286; 2007, No. 1, Art. 20, 39; No. 13, Art. 1465; No. 22, Art. 2563; No. 23, Art. 2691; No. 31, Art. 3991, 4013; No. 45, Art. 5416, 5417, 5432; No. 49, Art. 6045, 6071; No. 50, Art. 6237, 6245; 2008, No. 18, Art. 1942; No. 26, Art. 3022; No. 27, Art. 3126; No. 30, Art. 3611, 3614, 3616; No. 48, Art. 5500, 5504, 5519; No. 49, Art. 5723, 5749; No. 52, Art. 6237; 2009, No. 1, Art. 31; No. 11, Art. 1265; No. 18, Art. 2147; No. 23, Art. 2772; No. 29, Art. 3598, 3639; No. 30, Art. 3739; No. 39, Art. 4534; No. 45, Art. 5271; No. 48, Art. 5725, 5726, 5731, 5733, 5737; No. 51, Art. 6153, 6155; No. 52, Art. 6444, 6455; 2010, No. 15, Art. 1737, 1746; No. 19, Art. 2291; No. 25, Art. 3070; No. 31, Art. 4176, 4186, 4198; No. 32, Art. 4298; No. 45, Art. 5750, 5756; No. 47, Art. 6034; No. 48, Art. 6247, 6250; No. 49, Art. 6409; 2011, No. 1, Art. 7, 9, 21; No. 11, Art. 1492; No. 23, Art. 3262; No. 24, Art. 3357; No. 26, Art. 3652; No. 27, Art. 3881; No. 29, Art. 4291; No. 30, Art. 4583, 4587, 4593, 4597; No. 45, Art. 6335; No. 47, Art. 6610, 6611; No. 48, Art. 6729, 6731; No. 49, Art. 7014, 7015, 7016, 7037; No. 50, Art. 7359; 2012, No. 10, Art. 1164; No. 19, Art. 2281; No. 25, Art. 3268; No. 26, Art. 3447; No. 27, Art. 3588; No. 31, Art. 4334; No. 41, Art. 5526, 5527; No. 49, Art. 6750, 6751; No. 53, Art. 7596, 7604, 7607, 7619; 2013, No. 23, Art. 2866, 2889; No. 27, Art. 3444; No. 30, Art. 4031, 4048, 4049, 4081, 4084; No. 40, Art. 5038; No. 44, Art. 5640, 5645; No. 48, Art. 6165; No. 51, Art. 6699; No. 52, Art. 6985; 2014, No. 8, Art. 737; No. 16, Art. 1835, 1838; No. 19, Art. 2313; No. 23, Art. 2936, 2938; No. 26, Art. 3373; No. 30, Art. 4239; No. 40, Art. 5316; No. 48, Art. 6647, 6657, 6660, 6663; 2015, No. 1, Art. 5, 13, 15, 16, 17, 18, 32; No. 10, Art. 1402; No. 14, Art. 2023, 2024; No. 24, Art. 3373, 3377; No. 27, Art. 3968; No. 41, Art. 5632; No. 48, Art. 6684, 6686, 6688, 6689, 6692, 6693, 6694; 2016, No. 1, Art. 6, 16, 18; No. 7, Art. 920; No. 14, Art. 1902; No. 18, Art. 2504; No. 22, Art. 3098; No. 23, Art. 3298; No. 26, Art. 3856; No. 27, Art. 4175, 4176, 4180, 4181, 4182, 4184; No. 49, Art. 6841, 6843, 6844, 6847, 6848, 6849, 6851; 2017, No. 1, Art. 4; No. 11, Art. 1534; No. 15, Art. 2131, 2133; No. 30, Art. 4441, 4446; No. 40, Art. 5753; No. 45, Art. 6578, 6579; No. 47, Art. 6842; No. 49, Art. 7307, 7313, 7314, 7315, 7316, 7318, 7322, 7323, 7324, 7325, 7326; 2018, No. 1, Art. 20, 50; No. 9, Art. 1289, 1291; No. 18, Art. 2558, 2565, 2568, 2575; No. 24, Art. 3410; No. 27, Art. 3942; No. 28, Art. 4143; No. 30, Art. 4534; No. 32, Art. 5087, 5090, 5093, 5094, 5095, 5096; No. 45, Art. 6836, 6844, 6847; No. 47, Art. 7126, 7135; No. 49, Art. 7496, 7497, 7499; No. 53, Art. 8416, 8419; 2019, No. 16, Art. 1826; No. 18, Art. 2225; No. 22, Art. 2664, 2667; No. 23, Art. 2906, 2908, 2920; No. 25, Art. 3167; No. 27, Art. 3523; No. 30, Art. 4112, 4113, 4114; No. 31, Art. 4414, 4427; No. 39, Art. 5371, 5372, 5373, 5374, 5375, 5377; No. 52, Art. 7777, 7778; 2020, No. 12, Art. 1657; No. 13, Art. 1857; No. 14, Art. 2032; No. 17, Art. 2699; No. 24, Art. 3746; No. 29, Art. 4501, 4505, 4514; No. 30, Art. 4746; No. 31, Art. 5024; No. 42, Art. 6507, 6508, 6522; No. 46, Art. 7212; No. 48, Art. 7627; 2021, No. 1, Art. 9; No. 8, Art. 1198; No. 17, Art. 2887; No. 18, Art. 3047, 3048; No. 24, Art. 4214, 4217; No. 27, Art. 5133, 5136; No. 49, Art. 8146, 8147; 2022, No. 9, Art. 1250; No. 11, Art. 1597; No. 13, Art. 1955, 1956; No. 16, Art. 2598, 2599; No. 27, Art. 4597, 4612, 4626; No. 29, Art. 5206, 5230, 5288, 5290, 5291, 5301; No. 45, Art. 7676; No. 48, Art. 8307, 8310; No. 52, Art. 9350, 9353, 9379; 2023, No. 1, Art. 12, 43, 66; No. 8, Art. 1200; No. 9, Art. 1415; No. 18, Art. 3250; No. 23, Art. 4020, 4021; No. 26, Art. 4669, 4670, 4676; No. 32, Art. 6121; No. 43, Art. 7603; No. 45, Art. 7994; No. 47, Art. 8310, 8315; No. 49, Art. 8656; No. 52, Art. 9508, 9523, 9524, 9525; 2024, No. 1, Art. 24; No. 10, Art. 1312; No. 13, Art. 1672, 1681; No. 18, Art. 2405; No. 23, Art. 3038, 3059, 3061; No. 29, Art. 4105; No. 33, Art. 4955, 4979; No. 45, Art. 6693; No. 48, Art. 7207; No. 49, Art. 7407, 7409, 7421) following changes:

Item 2 of Article 146 to add 1) with the subitem 29 of the following content:

"29) transfer of goods (performance of works, rendering services) on a grant basis to the military units and the organizations of the Armed Forces of the Russian Federation, troops of national guard of the Russian Federation, bodies of the Federal Security Service which are state organizations provided that these goods (works, services) are transferred (are carried out, appear) for the purpose of their use by the specified military units and the organizations during the special military operation. The obtaining fact specified by military unit or data structure of goods (works, services) and the purposes of their use are confirmed by the document signed by the commander (head) of the specified military unit or the organization or person authorized by it.";

2) in paragraph six of the subitem 38 of Item 3 of Article 149 of the word "two billion rubles" shall be replaced with words "three billion rubles";

3) in Item 1 of Article 164:

a) add with subitem 9.4 of the following content:

"9. 4) services in transportation of passengers and baggage by high-speed railway transport in high-speed long distance railway Moscow - St. Petersburg (further in this subitem - high-speed long distance railway), rendered according to the concessionary agreement about financing, creation, operation of infrastructure of high-speed rail transport public, and also services in the organization of such transportations of passengers and baggage (further in this subitem - services in the organization of transportations).

For the purpose of this subitem services in the conclusion and execution of transportation agreements of passengers and baggage by high-speed railway transport in high-speed long distance railway, in the organization of distribution of travel documents (tickets) for driving through high-speed long distance railway, through implementation of collection and transfer to the customer according to the service provision agreement on the organization of transportations of the money which arrived as payment of travel documents (tickets) for driving through high-speed long distance railway, through verification of presence and validity of travel documents (tickets) for driving through high-speed long distance railway and through suppression of cases of stowaway journey, through operation, servicing and repair of high-speed railway rolling stock, passenger infrastructure of high-speed rail transport belong to services in the organization of transportations according to the admission of high-speed railway rolling stock to operation on infrastructure of high-speed rail transport, on check of operability of systems and other parameters of high-speed railway rolling stock, on management of high-speed railway rolling stock when implementing transportations on high-speed long distance railway, on preparation of the train schedule, on servicing of passengers, on placement, broadcast of information, including navigation nature, on objects of passenger infrastructure of high-speed rail transport, and also on ensuring compliance with transport safety in case of operation of high-speed railway rolling stock, on objects of passenger infrastructure of high-speed rail transport and objects of other infrastructure necessary for content, servicing and repair of high-speed railway rolling stock.

The services in the organization of advertizing, trading and other business activity specified in this subitem in high-speed railway rolling stock and on objects of passenger infrastructure of high-speed rail transport belong to services in the organization of transportations;";

b) state subitem 19 in the following edition:

"19) services in provision of places for temporary residence in hotels and other means of placement.

Provisions of this subitem are applied till December 31, 2030 inclusive if other is not established by this subitem.

The taxpayers rendering services in provision of places for temporary residence in hotels and other means of placement which are the objects of the tourist industry specified in paragraph one of the subitem 18 of this Item having the right to apply to the specified services the tax rate of 0 percent before the latest of the following dates:

On December 31, 2030 inclusive;

the last day of tax period (inclusive) in which twenty consecutive tax periods following tax period in which the corresponding object of the tourist industry was put into operation expire (including after reconstruction);";

4) in Article 165:

a) add with Item 5.6 of the following content:

"5.6. In case of rendering of services on transportation of the passengers and baggage provided by subitem 9.4 of Item 1 of Article 164 of this Code for confirmation of justification of application of the tax rate of 0 percent and the tax deductions in tax authorities the register of transportation (travel cards) documents on transportation of passengers and baggage with indication of in it numbers of the transportation (travel cards) documents determining route of transportation, the points of departure and appointment, date of rendering services, costs of services in transportation of passengers and baggage is submitted.

In case of rendering of services on transportation of the passengers and baggage provided by subitem 9.4 of Item 1 of Article 164 of this Code through the broker, the attorney or the agent on the commission agreement, the agreement of the order or the agency agreement for confirmation of justification of application of the tax rate of 0 percent and the tax deductions in tax authorities along with the register of transportation (travel cards) documents on the transportation of passengers and baggage specified in paragraph one of this Item the commission agreement, the agreement of the order or the agency agreement (the copy of the contract) of the taxpayer with the broker, the attorney or the agent is submitted.

In case of rendering of services on the organization of transportations of the passengers and baggage provided by subitem 9.4 of Item 1 of Article 164 of this Code for confirmation of justification of application of the tax rate of 0 percent and the tax deductions are represented to tax authorities:

contract or contract (copy of the agreement or contract) of the taxpayer for rendering services in the organization of transportations of passengers and baggage;

the act or other documents (their copy) confirming rendering services in the organization of transportations of passengers and baggage.";

b) in Item 15:

in paragraph one of figure "2.10" to replace with figures "2.8-1, 2.10, 2.13", after figures "9.3," to add with figures "9.4,";

the paragraph of the sixth after words "Item 3." To add 8, with words "subitems 2 - 4 Items 3.8-1, subitems 2 - 4 Items 3. 11,";

the ninth after figures "5.3," to add the paragraph with figures "5.6,";

Paragraph one of the subitem 2 of Item 3 of article 170 after figures "26" to add 5) with figures ", 29";

Shall be replaced with words 6) in Item 2.5 of Article 171 of the word "and 26" ", 26 and 29";

Item 5.2 of Article 179.7 to state 7) in the following edition:

"5.2. The federal executive body performing functions on development and realization of state policy and normative legal regulation in the field of fuel and energy complex annually till July 1 of the current year performs check of accomplishment of the actions specified in the agreement on upgrade of oil processing capacities, previous calendar year.

The federal executive body performing functions on development and realization of state policy and normative legal regulation in the field of fuel and energy complex terminates the agreement on upgrade of oil processing capacities unilaterally in case of violation of terms of realization at least of one of the actions provided by such agreement, except for:

violations of terms of realization and financing of the actions specified in such agreement, falling on the period of 2022 and 2023 on condition of their accomplishment till December 31, 2023 inclusive;

violations of terms of realization and financing of the actions specified in such agreement signed on the basis specified in the subitem 2 of Item 5 of this Article, falling on the period of 2023 on condition of their accomplishment till December 31, 2025 inclusive;

violations of terms of realization and financing of the actions specified in such agreement, falling on the period of 2024 on condition of introduction of amendments to the specified agreement concerning such actions according to the procedure, stipulated in Item 5.1 these Articles.

The federal executive body performing functions on development and realization of state policy and normative legal regulation in the field of fuel and energy complex notifies the organization which is the agreement party about upgrade of oil processing capacities, about agreement cancelation about upgrade of oil processing capacities within fifteen working days from the date of termination of the specified agreement.";

8) in paragraph seven of Item 8 of Article 217 of the word "50 thousand rubles" shall be replaced with words "1 million rubles";

Item 1 of Article 251 to add 9) with subitem 11.7 of the following content:

"11. 7) in the form of property (except for money), the works, services gratuitously received by the military unit or the organization of the Armed Forces of the Russian Federation, troops of national guard of the Russian Federation or bodies of the Federal Security Service which are state organizations provided that this property, works, services are received for the purpose of their use specified by military unit or the organization during the special military operation;";

10) Item 1 of Article 265:

a) add with subitem 19.12-1 of the following content:

"19.12-1) expenses in property cost type (except for money), the works, services donated to the military units and the organizations of the Armed Forces of the Russian Federation, troops of national guard of the Russian Federation, bodies of the Federal Security Service which are state organizations provided that this property, works, services are transferred for the purpose of their use by the specified military units and the organizations during the special military operation. The obtaining fact specified by military unit or the organization of this property (results of the performed works, the rendered services) and the purposes of its use are confirmed by the document signed by the commander (head) of the specified military unit or the organization or person authorized by it;";

b) add with subitem 19.15 of the following content:

"19. 15) expenses in the form of the amounts of the lump sum payments specified in paragraph seven of Item 8 of article 217 of this Code;";

11) in Item 2 of Article 266:

a) add with the new paragraph the eighteenth the following content:

"The bad debt (debt, unreal to collection) the debt on debenture interests of the foreign organization which are acknowledged as a part of the income according to provisions of subitem 14.4 of item 4 of Article of 271 of this Code, in case of accomplishment of the conditions specified in the subitem 12 of Item 2 of article 310 of this Code is also recognized.";

b) the eighteenth to consider the paragraph the paragraph the nineteenth;

Subitem 14.4 of item 4 of Article 271 to state 12) in the following edition:

"14. 4) the date determined according to Item 2 of Article 273 of this Code, but no later than December 31, 2029 - for the income in type of the percent added in 2023 - 2029 on debt obligations of the foreign organization before the taxpayer whose share of direct participation in this foreign organization constitutes more than 50 percent if concerning this foreign organization according to the legislation and (or) decisions of the courts of foreign state after March 5, 2022 rationing arrangements as a result of which charge of percent on obligations of this foreign organization to the taxpayer stops were established. For the purpose of this subitem for the income in type of the percent ranked as the main amount of debt, repayment date of the main amount of debt is considered the date of receipt of the income;";

Item 2 of Article 310 to add 13) with the subitem 12 of the following content:

"12) cases when the foreign organization gains income in the form of discharge regarding payment of outstanding amounts of percent in connection with forgiveness of debt on debt obligations of such foreign organization to the tax agent in case of accomplishment of the following conditions:

forgiveness of debt happens based on the agreement approved in foreign state judicially within financial improvement of such foreign organization;

the creditor - the tax agent and the borrower - the foreign organization are included into one international group of companies;

concerning such foreign organization date of discharge is affected by the prohibitive, rationing and (or) similar arrangements consisting in establishment of prohibitions and (or) restrictions for carrying out calculations and (or) implementation of financial transactions, prohibitions and (or) restrictions for carrying out the transactions connected with loan financing and (or) acquisition or alienation of securities (shares in the authorized capital), entered since 2022 by foreign states, economic, political, military or other associations of the countries, the international financial and other organizations.";

Item 2 of Article 346.5 to add 14) with the subitem 49 of the following content:

"49) expenses in property cost type (except for money), the works, services donated to the military units and the organizations of the Armed Forces of the Russian Federation, troops of national guard of the Russian Federation, bodies of the Federal Security Service which are state organizations provided that this property, works, services are transferred for the purpose of their use by the specified military units and the organizations during the special military operation. The obtaining fact specified by military unit or the organization of this property (results of the performed works, the rendered services) and the purposes of its use are confirmed by the document signed by the commander (head) of the specified military unit or the organization or person authorized by it.";

15) Item 1 of Article 346.16 to add with the subitem 44 following of content:

"44) expenses in property cost type (except for money), the works, services donated to the military units and the organizations of the Armed Forces of the Russian Federation, troops of national guard of the Russian Federation, bodies of the Federal Security Service which are state organizations provided that this property, works, services are transferred for the purpose of their use by the specified military units and the organizations during the special military operation. The obtaining fact specified by military unit or the organization of this property (results of the performed works, the rendered services) and the purposes of its use are confirmed by the document signed by the commander (head) of the specified military unit or the organization or person authorized by it.";

In paragraph four of the subitem 3 of Item 1 of Article 422 of the word "50 000 rubles" shall be replaced with words 16) "1 million rubles".

Article 2

1. This Federal Law becomes effective from the date of its official publication, except for provisions for which this Article establishes other term of their introduction in force.

2. Items 2 - 4, 8, the subitem "b" of Item 10 and Item 16 of article 1 of this Federal Law become effective after one month from the date of its official publication, but not earlier than the 1st of the next tax (settlement) period on the corresponding tax (insurance premiums).

3. Provisions of subitem 9.4 of Item 1 of Article 164 and Item 5.6 of article 165 of the Tax Code of the Russian Federation are applied to transactions on rendering of services on transportation (the organization of transportation) of passengers and baggage on high-speed long distance railway Moscow - St. Petersburg, performed during the period from January 1, 2028 to January 1, 2065.

4. Action of provisions of the paragraph of the eighteenth Item 2 of Article 266, of subitem 14.4 of item 4 of Article 271 and the subitem 12 of Item 2 of article 310 of the Tax Code of the Russian Federation (in edition of this Federal Law) extends to the legal relationship which arose since January 1, 2025.

5. Action of provisions of the subitem 29 of Item 2 of Article 146, of paragraph one of the subitem 2 of Item 3 of Article 170, of Item 2.5 of Article 171, of subitem 11.7 of Item 1 of Article 251, of subitem 19.12-1 of Item 1 of Article 265, of the subitem 49 of Item 2 of Article 346.5 and the subitem 44 of Item 1 of article 346.16 of the Tax Code of the Russian Federation (in edition of this Federal Law) extends to the legal relationship which arose since July 1, 2025.

6. Provisions of the paragraph of the eighteenth Item 2 of Article 266 and the subitem 12 of Item 2 of article 310 of the Tax Code of the Russian Federation are applied till December 31, 2029 inclusive.

 

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