Serbia Will Share Tax Information with Russia

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Russia’s Federal Tax Service (FTS) is preparing an updated list of countries and territories participating in the automatic exchange of country-by-country (CbC) reports. Nine jurisdictions, including Serbia, will be added to the list, while five UK-dependent offshore territories will be removed, Interfax reports.

The draft FTS order proposes excluding Anguilla, Bermuda, the British Virgin Islands, Gibraltar, and the Turks and Caicos Islands. They have suspended the exchange of reports with Russia in line with a decision by London under the Convention on Mutual Administrative Assistance in Tax Matters of 1988 (as amended in 2010).

At the same time, the list will be expanded to include nine countries—Antigua and Barbuda, Armenia, Botswana, Vietnam, Cabo Verde, Kenya, Mongolia, Serbia, and Montenegro—as well as the territory of Greenland. All of them joined the 2016 multilateral arrangement on the automatic exchange of country-by-country reports. For Belgrade, this signals institutional recognition of readiness for tax transparency and direct data exchange with Moscow.

Currently, 45 countries and 10 territories exchange information with Russia. After the update, those figures will change to 54 and six, respectively. Russia joined the global auto-exchange framework in 2016–2017, with the first information packages sent and received in 2018.

Special provisions were then added to the Tax Code, introducing the concept of an international group of companies required to submit country-by-country data. The largest corporations with consolidated annual revenue above €750 million must disclose information on revenues, expenses, profits, and taxes across all jurisdictions in which they operate. As a rule, the parent company files the report in its home country, and tax authorities exchange the information between themselves.

If a jurisdiction stops fulfilling its exchange obligations—as the UK territories have done—the FTS has the right to request the report directly from the Russian member of the group. The new draft order codifies this practice while widening the circle of partners. For Serbia, it is a step toward closer cooperation with Russia in tax control and the regulation of multinational business.

It is worth noting that this concerns companies rather than individuals—for now only large groups above the stated revenue threshold. Still, the trend is worrying for Russians who may be concealing income in Serbia from their country of citizenship.

Meanwhile, in Armenia, banks and brokers have already begun to collect from Russian clients information on tax residency, addresses, and taxpayer IDs in preparation for the first automatic exchange of data with the FTS under the CRS. Lawyers note that the first CRS exchange will cover not only individuals but also company beneficial owners. Armenia’s banking system is widely used for international settlements by Russian entities, including via companies in the UAE and Hong Kong. Many Russian citizens reside in the country and may face risks of double taxation and penalties for failing to disclose accounts and income.

The Finance Ministry and the FTS earlier reminded taxpayers that foreign accounts had to be reported by June 1, 2025. Under Federal Law No. 173-FZ “On Currency Regulation and Currency Control,” all residents are obliged to submit notifications and reports. The most common currency-control violation stems from failure to provide such information.

Citizens who have returned to Russia after living abroad must file notifications for all accounts that were not previously reported. Documents can be submitted via the taxpayer’s online account, on paper in person or through a representative, by registered mail, or electronically. There is dedicated FTS software—“Taxpayer LE” (Nalogoplatel’shchik YUL)—for preparing reports. Residents who were outside Russia for more than 183 days in a calendar year are exempt from reporting on foreign accounts.

Experts remind that a CIS protocol on exchanging data on income and taxes is already in force, but the CRS broadens access to information, including transit financial flows. In 2024, Russia registered nearly 137,000 administrative and criminal cases involving currency matters—up 72% year-on-year. The total amount of fines paid more than doubled the assessed sums. In 2025, the FTS plans to launch an automated system to determine residency status based on border-crossing records and passport data, narrowing room for maneuver for holders of foreign accounts.

Russia is tightening tax control both domestically and abroad. The center of cooperation is gradually shifting toward the CIS and “friendly” states, while Western jurisdictions suspend exchanges with Moscow. Georgia remains among the countries not sharing data. For Russian companies and individuals, this means closely tracking regulatory changes and taking advance steps to mitigate risks—from fines and account freezes to exposure to double taxation.

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