Sharing the case: tax amnesty will bring only 10 billion to the budget in 2025
The tax amnesty for business splitting will bring only 10 billion rubles to the budget in 2025, the Chamber of Commerce and Industry estimates. Approximately the same amount of money is annually added by the Federal Tax Service to organizations that chose to split up to avoid levies. In the context of the budget, this is a negligible amount. The authorities detect only a small share of violations, and in fact the problem is much broader - every year unscrupulous enterprises underpay more than 100 billion to the treasury. The proposed changes are unlikely to motivate firms to whitewash themselves, and the authorities may need show trials, experts say.
How the tax amnesty for splitting works
The budget will be replenished by about 10 billion rubles in 2025 thanks to the tax amnesty for business, estimated for "Izvestia" an expert of the Council for Financial, Industrial and Investment Policy of the Chamber of Commerce and Industry (CCI), tax consultant Alexei Krylov. Now companies are avoiding payments to the budget (this is why they split up growing enterprises), but the authorities do not identify all violators - as a result, the treasury receives less money. However, it is assumed that when organizations decide to whitewash themselves, they will independently pay this money to the budget.
The CCI calculations are based on the fact that now the tax authorities reveal violations of crushing for about 10 billion a year, and it is this amount that they force to pay extra money to the treasury. However, according to the estimates of the business association, the total budget underpayment from splitting is about 100 billion rubles a year. At the same time, according to Alexei Krylov, only some part of such violations is detected and suppressed.
The amnesty may bring additional 15-20 billion rubles to the budget this year, confirmed the calculations and associate professor of the basic department of financial control, analysis and audit of Plekhanov Russian Economic University Yulia Kovalenko. According to her, this will also be facilitated by the growing turnover of companies and the doubling of the thresholds for the simplified taxation system, up to 450 million: companies will simply become less profitable to violate the law.
Business splitting is an illegal division of a company into several legal entities or sole proprietorships. The scheme is used to distribute income between enterprises - most often it is resorted to by organizations that have gone beyond the thresholds of application of the simplified taxation system (in 2024 the limit was 265.8 million per year), which involves reduced rates of fees.
Amnesty for crushing became part of the tax fine-tuning. The mechanism works like this: a company that voluntarily abandoned an illegal scheme in 2025-2026 will have its debts for its use in the period from 2022 to 2024 written off - if the Federal Tax Service reveals that there were violations. The process has several nuances.
If the tax authorities conducted an on-site audit and did not find out about the split in 2025-2026, but in the previous three years there were such facts, then the need to pay additional fees for past periods ceases after the control measure. But if the company refuses such optimization only after the next audit, it will be exempted from additional charges only for 2022-2023, and for 2024 will specify the obligations.
If no audit was scheduled, but the company was previously split, the company will be exempted from liability only from 2030. That is, in the case of good faith behavior in 2025 and beyond, violations will be forgotten in five years - now the debts are just "hanging" over the payer.
When the result of market whitening will be visible
Although in the coming years the budget will hardly be significantly replenished thanks to the tax amnesty, but in the long term, companies will see the benefits of refusing illegal optimization, and the number of honest taxpayers will increase, believes Natalia Milchakova, a leading analyst at Freedom Finance Global.
The first noticeable result of market whitening will be seen already in the spring of 2026, when businesses will report on profit tax for 2025. Alexei Krylov from the Chamber of Commerce and Industry expects that interim results will appear by the spring of summer, i.e. after one or two VAT reporting periods. He is also sure that the treasury revenues will increase in the future.
In the context of the federal budget, 10 or even 20 billion is an extremely small amount: all revenues in 2025 are planned at the level of Br40 trillion. Nevertheless, it is comparable to the treasury's expenditures on some national projects: space development (10 billion) and food security (14.5 billion). A comparable amount of funds under the presidential decree will also be allocated to increase salaries in the cultural sector (11.6 billion).
Budget revenues as a result of the amnesty will indeed increase, agreed Ekaterina Avdeeva, head of the Delovaya Rossiya expert center for criminal law policy and enforcement of judicial acts. She added: at the same time, the income collected in the form of underpayments through the court will fall out, but it is about one tenth of the damage from the crushing of business. According to Andrei Barkhota, candidate of economic sciences, the volume of underpayments due to fragmentation can be reduced by two or three times in 2025.
"Izvestia" asked the Ministry of Finance about the budget damage from business fragmentation in 2024. The ministry advised to turn to the Federal Tax Service. The editorial board sent a request to the service.
Will the amnesty stimulate legalization of business?
Now the topic of splitting is one of the most discussed in the business environment, said Alexei Krylov from the Chamber of Commerce and Industry. He added: entrepreneurs still have a number of questions about the amnesty - for example, how they can independently determine the signs of division in their activities.
The amnesty in its current form has several pitfalls that may make the measure not as successful as the Federal Tax Service expects, said Ekaterina Avdeeva, head of the Delovaya Rossiya expert center for criminal law policy and enforcement of judicial acts. First of all, in some industries there is an acute question of what part of companies will take the opportunity to legalize.
The fact is that nowadays so sophisticated schemes of division are used that it is possible to uncover them and prove them in court only on the basis of operational work, and the resources of law enforcement officers are objectively limited, the expert added. Therefore, many companies may think that this threat simply will not affect them.
- There is a possibility that many companies will prefer to take an "ostrich position" and hide their heads in the sand. Perhaps a precedent case will be needed, as in the case of Blinovskaya and other bloggers," Ekaterina Avdeeva believes.
In 2023, several bloggers were criminally prosecuted for non-payment of taxes, including through business splitting. For example, the amount of claims of the Federal Tax Service to Elena Blinovskaya amounted to 1.4 billion rubles, of which only penalties and fines - about 230 million. In addition, debts were found at Valeria and Artem Chekalin - in the amount of 500 million, including sanctions. Alexandra Mitroshina also paid a large underpayment (for 127 million).
Ruslan Kuleshov, General Director of the law firm "Clean Environment", also believes that many companies will be more affected by the strengthening of control work of tax officials than by the voluntary amnesty.
Most likely, in 2025 the main "candidates" to work out the fight against crushing will be sellers on marketplaces, says Alexei Krylov from the Chamber of Commerce and Industry. In particular, this is evidenced by the agreement between the Federal Tax Service and representatives of the largest online marketplaces.
- It is no secret that many sellers artificially divide revenue streams between interdependent entities (for example, between IE-relatives) in order to maintain the limits for "simplification", - said the expert.
Among other "candidates" are wholesalers who mimic a lot of small sellers, continued Alexei Krylov. He added: they can also be logistics or construction companies.
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