Russia Clarifies Requirement to Amend Consolidated Group Agreement for Liquidation/Reorganization

The Russian Ministry of Finance has issued guidance letter No. 03-12-11/3/5406 of 31 January 2018 concerning the requirements to amend an agreement for a consolidated group of taxpayers (CGT) when there is a liquidation or reorganization of members of the CGT. The letter provides that an agreement amending the original CGT agreement must be registered with the tax authorities within one month of:

• A decision to liquidate one or more members of the CGT; and
• A decision for a reorganization (mer…