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Insights / Tax & compliance
Tax & compliance · 7 min

Pillar 2 in Russia: the 15% minimum tax and who it actually hits

Something big arrived quietly — Russia's own 15% minimum tax from 2026. Whether it hits your group, and if the four conditions all apply, what the top-up means for your effective rate, is the question to get ahead of.

TW
TaxWell & Partners
Tax & legal advisers · reviewed for 2026 rules
7 min read
It may apply if

You're part of a large multinational group whose Russian effective rate falls below 15% — all four conditions have to align.

What it means

A top-up to bring the effective rate to 15%, which can surface as a liability no one modelled if the conditions aren't checked.

15%
the minimum effective rate
4
conditions that must align
top-up
the resulting liability

Russia now has its own version of the global minimum tax, and it arrived with less noise than its significance warrants. Federal Law No. 425-FZ, signed on 28 November 2025, sets a 15% minimum effective profit tax rate for Russian companies that belong to multinational enterprise groups. It applies from 2026. The Ministry of Finance drafted it in direct response to Pillar 2 being adopted across OECD countries, and the logic is defensive rather than revenue-hungry: if a Russian subsidiary is taxed below 15%, somebody was going to collect the difference. Russia has decided it should be Russia.

01

The concept, in one line

Pillar 2 rests on a simple idea — profits in every jurisdiction where a group operates should be taxed at no less than 15%, and where they are not, a top-up brings the effective rate up to that floor. The OECD rules collect that top-up at the level of the parent, or failing that across other group jurisdictions. A country that introduces its own domestic minimum tax collects it locally first, and keeps the money. That is what Russia has done.

02

Who is in scope

The Russian rules apply where all four of the following are true:

The parent company of the group is foreign.

The parent, an intermediate holding company or another group entity is resident in a country that has adopted Pillar 2 — the list of those countries is to be set separately by the Russian Ministry of Finance.

The group's consolidated annual revenue exceeded €750 million in each of the two fiscal years preceding the tax period.

The effective tax rate of the Russian group member is below 15%.

The revenue test deserves a second look. The OECD's standard formulation is €750 million in at least two of the last four fiscal years; the Russian test is framed as each of the two preceding years. If your group sits near the threshold and revenue is lumpy, that difference is not academic.

03

The Russian twist: per entity, not per jurisdiction

This is the most significant departure from the OECD model and the one most likely to catch groups out. Under Pillar 2 as the OECD wrote it, the effective tax rate is computed for a jurisdiction as a whole — all your Russian entities blended together. Under the Russian rules, it is computed for each Russian group member separately.

Large group unsure about the minimum tax?

Pick what applies — we'll tell you if it hits:

We're a multinational with Russian profit →Our effective rate may be under 15% →We need to know if the four conditions apply →

The practical consequence is that you cannot offset. A group with one Russian entity paying 25% and another sitting in a special economic zone at a low single-digit rate would blend to something comfortably above the floor under the OECD approach. Under the Russian rules the zone entity is assessed on its own, and tops up on its own.

04

Why most foreign groups will not pay it

This is worth saying plainly, because the headline invites the opposite conclusion. Russia's standard corporate income tax rate is 25% — ten points above the Pillar 2 floor. An ordinary foreign-owned Russian trading or service company paying CIT at the standard rate has an effective rate well clear of 15% and will owe no top-up at all.

If that describes your Russian entity, these rules are an administrative question — can you demonstrate the position if asked? — rather than a cash one. That is a very different conversation from the one the words "global minimum tax" tend to start.

05

Where it actually bites

The exposure sits with entities on a preferential rate. The regimes in the frame include:

Residents of special economic zones

Residents of advanced development territories

Residents of the free port of Vladivostok

Parties to special investment contracts

Parties to agreements on the protection and promotion of capital investments

International holding companies

Participants in the free economic zone covering the DPR, LPR, Zaporizhzhia and Kherson regions

There is an irony here worth naming. These regimes exist to attract investment by lowering the tax rate. A minimum tax takes the benefit back, and the only real question is which treasury receives it. From the Russian state's perspective, collecting the top-up domestically beats watching a foreign parent's jurisdiction collect it. From an investor's perspective, an incentive that is clawed back is not an incentive — and any model built on the headline preferential rate needs rerunning.

06

Dormant companies are not exempt

The rules set no activity requirement for the Russian group member. A dormant company — not trading, no staff, kept alive pending a decision about the market — sits inside the scope test if the group does. This matters for the many foreign groups that have parked a Russian entity rather than closing it. If that entity has any profit and a low effective rate, it can generate a top-up obligation while doing nothing at all.

07

What to do now

The realistic first step is a scoping exercise, not a calculation. Establish whether the group meets the revenue test, whether the parent's jurisdiction lands on the Ministry's list once it is published, and whether any Russian entity is on a preferential rate. Most groups will finish that exercise and stop, having established they are either out of scope or comfortably above the floor.

For those who are not, the work is real: the effective rate has to be computed for each entity, the interaction with the parent's own Pillar 2 position has to be assessed so the same profit is not taxed twice, and the budget has to be adjusted. None of it improves with delay, and the first affected period is already running.

Frequently asked questions
Does Pillar 2 apply in Russia?

Yes, from 2026. Russia has not adopted the OECD rules themselves but enacted a domestic equivalent — Federal Law No. 425-FZ, signed on 28 November 2025 — setting a 15% minimum effective profit tax for Russian members of multinational groups.

Our group is above €750 million but our Russian subsidiary pays CIT at 25%. Are we affected?

Almost certainly no top-up is payable. The Russian standard CIT rate of 25% is ten points above the 15% floor, so an entity paying it has an effective rate well clear of the threshold. You may still want the scoping position documented, but this is an administrative exercise rather than a cash one.

How do the Russian rules differ from OECD Pillar 2?

The important difference is that the effective tax rate is calculated for each Russian group member separately, whereas the OECD rules blend a jurisdiction as a whole. That removes the ability to offset a low-taxed entity against a normally taxed one. The revenue test is also framed differently — each of the two preceding fiscal years, rather than the OECD's two of the last four.

We are a US-headquartered group. Does this affect us?

It needs checking rather than assuming. In January 2026 the US Treasury announced that US-headquartered companies would be exempt from Pillar 2's requirements and that the US will not implement the rules. That does not automatically place a Russian subsidiary outside the Russian rules: the Russian test asks whether the parent, an intermediate holding company or another group entity is resident in a country that has adopted Pillar 2 — so an intermediate holding in an adopting jurisdiction can still bring the group into scope.

Does it affect a dormant Russian company?

It can. The rules set no activity requirement, so a dormant entity is inside the scope test if the group is. If it has any profit and a low effective rate, a top-up can arise while the company does nothing. Groups that parked a Russian entity rather than closing it should check.

What happens to our special economic zone benefits?

Where the preferential rate takes the entity's effective rate below 15%, the minimum tax tops it back up to the floor. The regimes affected include SEZ and advanced development territory residents, the free port of Vladivostok, special investment contract parties, capital investment protection agreements and international holding companies. The benefit is not withdrawn as such — but its value above the floor is.

Related service: Tax & compliance →
+ how we can help

This flags something big that arrived quietly — Russia's own 15% minimum tax from 2026. Your question is whether it hits your group, and if the four conditions all apply to you, what the top-up actually means for your effective rate.

Pillar 2 applicability — Whether all four conditions catch your group — before a top-up liability appears that no one modelled.
Effective-rate review — Your Russian effective rate tested against the 15% floor, so you know if a top-up arises and how much.
Compliance & planning — The reporting and any planning room handled, so the minimum tax is managed rather than discovered.

Part of a large multinational group? Worth checking now whether the 2026 minimum tax reaches you, before it's a filing.

Ask about Pillar 2 →Book a 30-min call
Or read how we handle Tax & compliance →
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