Russian Federal Tax Service Explains When Minimum Top-up Tax Applies

The Russian Federal Tax Service recently issued a notice on the new corporate income tax rules that apply to Russian constituent entities of MNE groups starting from 2026. In particular, the notice addresses the 15% minimum tax (top-up tax) introduced as part of Federal Law No. 425-FZ of 28 November 2025.

For the top-up tax rules to apply, the following conditions must be met simultaneously:

• The Ultimate Parent Entity (UPE) of the MNE group is a tax resident of a foreign jurisdiction as o…