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Russian Federation Corporate - Deductions

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Expenses are deducted on an accrual basis. The main criteria for deductibility of expenses is that the expense is properly documented, aimed at generating income, and not specified in the RTC as non-deductible for tax purposes.

Depreciation and amortisation

Two methods of depreciation are allowed: the straight-line method and the declining-balance method. The useful lifespans of assets for tax purposes are established in the Classification of Fixed Assets, which was approved by the Russian government, for example:

Fixed asset Useful life (years)
Personal computer 2 to 3
Automobile 3 to 5
Truck (capacity above five tonnes) 7 to 10
Aircraft 10 to 15
Blast furnace 20 to 25

Accelerated depreciation is permitted in respect to some types of property (a special ratio of up to three may be applied). It is prohibited to apply several special coefficients to a normal rate of depreciation.

An upfront premium is allowed, which means that a taxpayer has the right to deduct 10% (or 30% for certain categories of fixed assets) of the cost of fixed assets purchased (or built) in the month when the depreciation started. The balance is depreciated over the useful life of the asset. A premium must be recaptured if a relevant asset is sold within five years of its acquisition (the requirement to recapture has not applied to sales to unrelated parties since 2013).

Intangible assets are amortised over their useful life, or over ten years (two years for certain types of intangible assets) if their useful life cannot be determined.

Starting from 2018, a new tax benefit stimulating the renewal of fixed assets applies. Taxpayers will have a choice to use depreciation or to deduct the cost of investment (cost of fixed assets acquired) directly from the CIT. The choice is available in constituent regions where an appropriate law is adopted. Up to 90% of expenses can be deducted from the regional CIT and up to 10% from the federal CIT. Considering this, the amount of regional CIT must be at least 5% of the tax base before applying the deduction. The amount of federal CIT may be reduced to zero. The Russian regions may set a cap on the amount of the deduction. If the amount of investments exceeds the set cap, it may be carried forward for unlimited number of years. The deduction is applicable only to newly commissioned (or modernised) assets with a useful life of 3 to 20 years (e.g. buildings, machinery, transport). Only a few Russian regions have introduced the benefit, as it is associated with a temporary decrease in tax collection. There is no information as to whether the regime will be introduced in Moscow and St. Petersburg.

Goodwill

Under Russian tax law, a mark-up (the difference between the acquisition value and net assets of the business [property complex] purchased) should be recognised as goodwill for tax purposes and may be amortised by a buyer over five years. However, this tax regime often does not apply since a business (subject of a deal) needs to be registered as a property complex with the government authorities. However, sellers almost never do this.

Start-up expenses

Russian tax law does not contain specific provisions on the deductibility of start-up expenses. In some cases, they may not be deducted by either a parent company or a subsidiary for tax purposes.

Interest expenses

The tax authorities can audit interest income and expenses only for transactions that are deemed as controlled under Russian transfer pricing rules (this means transactions with related parties in most cases) and only in accordance with these rules.

The following table shows how the market corridors (safe harbours) are applied to interest accrued:

Debt currency Type of loan Safe harbour rates
Russian rubles (RUB) Ruble-denominated loans between Russian entities 75% to 125% of the Central Bank of Russia (CBR) key rate
Other ruble-denominated loans 75% to 125% of the CBR key rate
Euros (EUR) Foreign currency-denominated loans EURIBOR +4% to EURIBOR +7%
Chinese renminbi (CNY) SHIBOR +4% to SHIBOR +7%
British pounds (GBP) LIBOR in GBP +4% to LIBOR in GBP +7%
Swiss francs (CHF) or Japanese yen (JPY) LIBOR in relevant currency +2% to LIBOR in relevant currency +5%
Other LIBOR in United States dollars (USD) +4% to LIBOR in USD +7%

The CBR’s key rate has been 7.75% since 17 December 2018.

Free-of-charge loans between Russian related parties are not controlled under transfer pricing rules.

Bad debt

Losses in the form of bad debts written off are usually deductible. Companies may create a bad debt provision. The method of accrual for the provision for tax purposes may differ from that in financial accounting, as it is based only on the overdue payment period (i.e. if the delay exceeds 90 days, the full amount of the account receivable is included in the reserve).

A tax deductible bad debt provision can be created only to the extent of the excess of amounts receivable over amounts payable (if any) to the same counterparty.

Charitable contributions

Russian tax law does not provide any benefits with respect to charitable contributions. Such expenses are not deductible for tax purposes.

Research and development (R&D) expenses

R&D expenses (including R&D with a negative result) are deductible within one year after completion. Certain R&D expenses may be deducted using a coefficient of 1.5. The list of R&D categories is determined by the Russian government. A provision for future R&D expenses may be accrued for tax purposes.

Insurance premiums

Expenses related to all types of obligatory insurance are deductible and subject to government tariff limitations, wherever established. Voluntary insurance expenses are deductible to the extent that they relate to the insurance of damage and losses related to certain classes of assets, and the insurance of construction activity risks. Contract liability insurance expenses are deductible to the extent that such insurance is required by an international treaty to which Russia is a party or a generally accepted international trade custom.

Long-term life and pension insurance is deductible within a limit of 12% of the payroll fund. Voluntary medical insurance is deductible within a limit of 6% of the payroll fund.

Fines and penalties

Fines and penalties paid to contractors for violating contractual terms may be deducted for tax purposes.

Fines and penalties paid to a government budget are not deductible.

Taxes

Taxes paid by a taxpayer, as well as social contributions of employers, are deductible for tax purposes. Trade levies are credited against CIT.

Net operating and capital losses

The amount of a recognised loss of prior periods cannot exceed 50% of the current year tax base for CIT purposes. This limitation applies from 2017 through 2020. Starting from 2021, recognition of the entire amount of losses will be possible again.

At the same time, the limitation on carryforward of losses for a ten-year period has been abolished in principle (which means that losses incurred since 2007 may be carried forward until fully recognised).

Carryback of losses is not allowed.

Losses from the sale of fixed assets are recognised evenly during the remaining useful life.

Losses and income from different tax baskets are determined separately (see Capital gains in the Income determination section for more details).

Payments to foreign affiliates

There are no special tax provisions with respect to the deductibility of payments to foreign affiliates for services provided. They may be deducted in full if general deductibility criteria are met. Charges with respect to administrative support provided by foreign affiliates may be deductible. However, due care should be taken with regard to the documents used to support the nature and actual receipt of service.


Last Reviewed - 25 January 2019

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