On November 28, 2025, the President of the Russian Federation signed Federal law No. 425-FZ establishing a minimum effective profit tax rate of 15% for Russian companies that are part of multinational enterprises (MNE) groups. The changes will come into force starting 2026.
The bill was drafted by the Russian Ministry of Finance in response to the launch of Pillar 2 in the OECD countries. The Pillar 2 rules are based on a fairly simple concept: taxation of profits in each jurisdiction where an MNE group is present at a rate of at least 15%.
The new profit tax calculation rules will apply if the following conditions are met:
- the parent company of the MNE group is located abroad;
- the parent company, intermediate holding company, or any other MNE group organization is a resident of a country that has joined Pillar 2 (the list of jurisdictions will be separately agreed upon by the Russian Ministry of Finance);
- the consolidated annual revenue of the MNE group for each of the two preceding financial periods exceeds 750 million EUR;
- the minimum effective rate for each Russian member of the MNE group is less than 15%. An important difference between the Russian rules and Pillar 2 is that the effective tax rate is calculated individually for each company (under Pillar 2, the calculation is made for the jurisdiction as a whole).
If all of the above conditions are met, the Russian participant of the MNE group will have to pay additional profit tax in the Russian Federation at a rate of 15%. The changes do not provide any other requirements for such a participant in the MNE (e.g. level of activities, industry, etc.), and might affect any Russian MNE participant.
In connection with the introduction of the new rules, we recommend assessing the potential tax impact on the MNE group and its Russian participants in terms of budgeting, administrative burden, and potential double taxation.
KBK Accounting is ready to offer its services, including:
- diagnostics of the impact of the new rules on the MNE group;
- assistance in calculating additional tax payments or review of calculations;
- analysis of the effect of the local minimum tax equivalent on additional payments in Russia.
Should you have any questions, please do not hesitate to contact KBK Accounting
KBK Accounting OOO
Pokrovskij bulvar 4/17, Geb. 1, Büro 21
101000 Moskau
Russian Federation
+7 (495) 662 33 30
info@kbk-accounting.de
www.kbk-accounting.de