What happens if nobody files
The FTS treats a foreign-owned dormant company as a live taxpayer. Missed CIT, VAT, or insurance filings produce penalties and late interest; repeated non-filing can freeze accounts, disqualify the director, and move the inspector toward forced liquidation — which is slower, costlier, and harder to explain to a board than a planned wind-down.
- Penalties and interest on each missed form, stacking by quarter
- Account freeze and blocked digital signature / reporting channel
- Director disqualification and EGRUL “unreliable” marks
- A forced liquidation that the parent does not control
What it is
A company that still trades has a full tax cycle: CIT, VAT, payroll, correspondence with the FTS. A company that does not trade still files. Russian law has no quiet “we left in 2022” status. A legal entity on EGRUL must file even with no staff and a blocked account. Nil returns are still returns. Silence is a violation.
Colibry runs that cycle through our affiliated Russian company and its in-house tax specialists. The U.S. parent does not prepare, sign, or submit a Russian filing, and does not originate a payment in Russia. You receive an English calendar, copies, and a quarterly risk note.
From 2025 the Russian corporate income tax rate is 25%, not 20%. Double-tax treaties with a long list of “unfriendly” jurisdictions, including the United States, remain suspended — so leftover dividend or liquidation distributions, if they ever move, face domestic withholding (typically 15%), not the old treaty rate. None of that turns a dormant company into a non-filer. Nil VAT and CIT returns are still the posture until EGRUL deletion.
The work is administration, not a tax opinion for the parent’s U.S. return. Where a filing position is material, we flag it for your U.S. and Russian counsel before it goes in. Copies are packaged so a parent auditor can see what was filed without reading Russian forms raw.
What is in scope — and what is not
We do
- Corporate income tax (CIT) at the current statutory rate (25% from 2025) — quarterly advances and the annual return, including nil
- VAT — quarterly returns, including nil where activity has ceased
- Property tax and transport tax where the entity still holds assets
- Insurance premiums (RSV) and employee reporting (6-NDFL, personalized accounting) where a payroll remnant exists
- Accounting statements to the FTS and Rosstat (balance sheet and P&L)
- Statistical and industry-specific forms that still apply to the OKVED codes on the register
- Withholding positions on any leftover payment (treaty relief is generally unavailable while DTTs stay suspended)
- Written responses to FTS information requests and desk-audit letters
- A live English filing calendar with four-week deadline warnings and a copy pack for the parent’s auditors
We do not
- U.S. federal or state tax returns for the parent
- Transfer-pricing documentation as a standalone expert report (we can coordinate)
- Continuing prohibited commercial operations in Russia
- Signing filings as a U.S. person or from a U.S. workstation
How the work runs
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01
Intake audit
We collect the last filed pack, EGRUL extract, accounting database or trial balance, and any open FTS paper. Gaps become the first-cycle worklist.
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02
Calendar
A one-page English calendar of CIT, VAT, RSV, accounts, and statistics for the entity’s actual profile — not a generic Russia checklist.
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03
In-country filing
The affiliate prepares, signs, and submits. You see the draft status in English before anything material goes in.
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04
Quarterly report
What was filed, when, copies, FTS reactions, and the next four weeks. Unusual letters are same-cycle, with a risk note.
Calendar
| When | What |
|---|---|
| Each quarter | VAT; CIT advances; RSV / payroll remnants if any |
| Year-end | Annual CIT, accounting statements, Rosstat pack |
| Ad hoc | FTS requests — response windows are short; we treat them as emergency work |
| Continuous | Law-change watch on forms that apply to this entity only |
What we need to start
Missing items are a workstream, not a reason to wait. A signed note that a year of filings does not exist is more useful than another month of silence.
- Current EGRUL extract and charter (ustav)
- Last two years of filed CIT, VAT, RSV, and accounts if they exist
- Accounting database (1C or export) or a trial balance
- Director and participant list, with passport scans for the nominee change if needed
- Any FTS, court, or bank letters already received
- A short note on whether the entity is dormant, winding down, or still has residual contracts
Reporting
Quarterly English compliance report: filing status, copies, identified risks, recommended actions. Deadline warnings at least four weeks out. FTS paper the day we have it.
Who it is for
U.S. and other Western parents with a Russian subsidiary — operating or quiet — that cannot, or will not, staff a local finance function.
We will not take
- Groups seeking to restart ordinary trade into Russia
- Entities that are SDN, blocked, or 50-percent owned by a listed party
Fees and start
Fixed-scope engagements with fees agreed in advance. Pricing is set after an initial consultation at no charge. Onboarding and initial audit: 2–3 weeks. Ongoing service follows the Russian tax calendar. See how the New York contract works and the week-one document pack.