The Federal Tax Service Will Check All Cross-Border Transfers Over Three Years: Sham Loans and Advances in Focus

The tax authority is analyzing Central Bank data to identify schemes for moving capital abroad

The Federal Tax Service has launched a large-scale review of cross-border payments made by Russian companies in 2023–2025. The agency is comparing Bank of Russia macrodata with its own reporting to identify sham services, multi-year loans, and advances, RBC reports, citing Mikhail Volkov, head of the FTS international taxation department division.

We took the Bank of Russia macrodata and realized there was something to work with. We overlaid it with our data and understood that there are certain risks. These are the years 2023, 2024, and 2025
Mikhail Volkov, head of the FTS international taxation department division at the Litigation City conference

Transactions involving any jurisdictions are coming under scrutiny, both friendly and unfriendly. Special attention will be paid to "50-year loans" and advances for services not rendered, with the FTS refining its detection methodology based on court practice.

For some industrial enterprises, this means tighter control over settlements with foreign counterparties. Schemes involving sham imports of services or long-term lending to affiliated structures abroad have traditionally been used for covert capital flight, bypassing investment in production modernization.

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