On 7 January 2026, the United States executed coordinated interdiction operations at sea under its sanctions enforcement regime, seizing two oil tankers, the Marinera (formerly Bella 1) in the North Atlantic and the Sophia in the Caribbean Sea, for alleged violations of U.S. sanctions targeting the “shadow fleet”.
General
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Extended simplified redomiciliation to special administrative regions
Until the end of 2026, Russia extended the availability of a simplified procedure for the redomiciliation of companies to its special administrative regions, facilitating the transfer of corporate registration from foreign jurisdictions to Russian legal territory.
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Revised rules for forced securities conversion
Russia revised the rules governing the forced conversion of securities issued by foreign companies into shares of an international company. The measure enables coercive conversion of foreign-issued securities into Russian entities, reducing investor protections while strengthening state control over assets affected by sanctions.
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EU Uses Article 122 TFEU to Permanently Immobilise Russian Central Bank Assets
The Council of the EU adopted Regulation 2025/2600 under Article 122 TFEU, allowing it to immobilise Russian Central Bank assets by qualified majority voting rather than unanimity. This legal shift removes the recurring six-monthly renewal requirement that had governed the asset freeze since 2022 and eliminates the risk that a single Member State could veto or allow the measures to lapse.
For Russia, the consequences are substantial. Approximately €210 billion in Central Bank assets remain locked in the EU on a “temporary but potentially indefinite” basis. Unfreezing is now conditional on Russia ending its war of aggression, paying reparations to Ukraine, and no longer posing serious economic risks to the EU. The decision also lays the legal groundwork for potentially using the immobilised funds to support Ukraine’s reconstruction.
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Transport tax exemption for agricultural vehicles
Vehicles registered to agricultural producers and used directly in agricultural activities for the production of agricultural goods are exempt from transport taxation.
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Higher excise taxes on transport and fuel
In 2026, excise tax rates on road transport vehicles and on motor fuels will be raised, increasing taxation on transportation and energy consumption.
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Lower VAT thresholds for SMEs
Russia introduces a phased reduction in the income thresholds triggering VAT obligations for small and medium-sized enterprises (SMEs). From 2026, VAT applies once annual income exceeds 20 million rubles; from 2027, the threshold is reduced to 15 million rubles; and from 2028, to 10 million rubles. Once the threshold is exceeded, SMEs must pay VAT either at reduced rates of 5% or 7%, or at the standard rate of 22%. This change increases the fiscal burden on SMEs by expanding the number of firms subject to VAT and raising their effective tax liabilities.
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VAT exemption retained for Russian software
The VAT exemption for the sale or licensing of rights to domestically developed software is maintained for Russian software developers, preserving preferential tax treatment for their own intellectual property.
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Mandatory education spending for large IT firms
Large IT companies—defined as having at least 100 employees and annual revenues exceeding 1 billion rubles—that hold state accreditation and receive tax benefits are required to conclude cooperation agreements with universities on educational programs for training qualified IT specialists. These companies must also allocate at least 3% of the funds saved through tax benefits to support such educational activities.
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Higher VAT and minimum tax for multinationals
From 1 January 2026, the standard value-added tax (VAT) rate will be increased from 20% to 22%. In addition, a minimum tax level is introduced for members of international corporate groups, requiring Russian subsidiaries of multinational holdings to pay corporate income tax in Russia at an effective rate of at least 15%, rather than shifting taxation to foreign jurisdictions.