Western groups often treat “we ceased operations in 2022” as an operational fact and, wrongly, as a legal one. Russian tax administration does not have a dormant election that turns the company off. Corporate income tax, VAT, and — where a payroll remnant exists — insurance reporting continue until the entity is deleted from EGRUL.
Nil VAT and CIT returns are the correct posture for a true dormant profile. They are also the first thing an inspector asks for when a letter finally arrives. A two-year gap is not a quiet period. It is a reconstruction project, usually with penalties.
The practical sequence for most U.S. parents is: confirm the register status, put a reachable director and address in place, file the missing nils or reconstruct, then decide whether to hold or to liquidate. Holding without filings is the expensive option, not the conservative one.
Takeaways
- Check EGRUL before you assume the company is “already gone.”
- Budget a 2–3 week onboarding audit before the first clean quarter.
- If the board wants out, start liquidation on a live, filed company — not on a gap.
This is not legal advice. See the legal notice and the sanctions framework.