Significant tax amendments were adopted in November 2025, and a new procedure for recovering individuals' tax debts came into force. The immediate task for businesses is to prepare for the changes taking effect in 2026, distinguishing them from rules already in force and initiatives still under discussion.
Tax reform and administration are central to November's agenda. In investment matters, the special conditions governing foreign capital remain relevant. These issues concern different parties and timeframes; they do not imply a general requirement to restructure every corporate group immediately.
Tax reform and the Russian Tax Code
Federal Law No. 425-FZ of 28 November 2025 amends a number of provisions of the Tax Code. From 1 January 2026, the standard VAT rate rises from 20% to 22%. For VAT exemption under the simplified taxation system in 2026, the previous year's income threshold is reduced to RUB 20 million.
Companies need to assess the new conditions against their income, prices and contracts. Exemptions and special rates require separate consideration; a higher standard rate does not mean an identical increase in the burden on every transaction.
Changes to tax administration
Since 1 November 2025, Federal Law No. 287-FZ of 31 July 2025 has provided an out-of-court procedure for recovering tax debts from individuals who are not registered as individual entrepreneurs. It may also affect people paying tax on professional income who do not have individual entrepreneur status.
The procedure applies to undisputed debt. Where objections are submitted as provided for by law, the disputed amount is recovered through the courts. It is therefore important to check tax authority demands and submit objections in time; the procedure does not entail automatic debiting of every disputed assessment.
Electronic documents and compliance risks
Certain formats for electronic primary accounting documents are changing at the start of 2026. From 1 January, the Federal Tax Service's approved formats for electronic goods delivery notes and certificates of completed work cease to apply; the Service recommends the universal transfer document format for electronic exchange.
This change in formats does not abolish the use of electronic document exchange operators. Companies should check the formats they use and the readiness of their accounting systems, while distinguishing primary accounting documents from channels of communication with the tax authority.
Foreign investment and counter-sanctions rules
In investment matters, the special regime already established under Presidential Decree No. 436 of 1 July 2025 remains important. It provides for type “In” accounts for certain transactions by foreign investors; the rules for these accounts were established by a decision of the Bank of Russia's Board of Directors dated 31 July 2025.
This framework was already in force by November; it is not a new November measure. Whether a particular transaction is possible depends on the conditions of the special regime, which does not amount to a general removal of restrictions on foreign investors.
Practical implications for Resolutum clients
Before the end of the year, companies should assess the effects of the tax amendments on their activities and prepare the electronic document formats they use. For debt recovery, the existence of a dispute and the deadlines for objections are significant. Investment decisions require a separate review of the applicable regime, rather than an assumption that conditions have generally eased or tightened.