Notification of participation in foreign organizations. Notice of participation in a foreign organization Grounds for filing

C.V. Razgulin

active state adviser of the Russian Federation, class 3

Since 2015, Federal Law No. 376-FZ of November 24, 2014 introduced the obligation of taxpayers, including individuals, to notify tax authorities about participation in foreign organizations and the establishment of foreign structures without forming a legal entity. Moreover, already by Federal Law No. 85-FZ of April 6, 2015, the deadlines for fulfilling this obligation were changed in relation to the previously arisen participation in foreign organizations (previously established structures). This interview is devoted to the procedure for notification of participation in foreign persons.

- Who should report participation in foreign organizations? Do individuals have such a duty?
Clause 3.1 of Article 23 and Article 25.14 of the Tax Code of the Russian Federation oblige all taxpayers who are tax residents of the Russian Federation to send notifications to the tax authorities on participation in foreign organizations.

Taxpayers - tax residents of the Russian Federation in accordance with Articles 207, 246.2 of the Tax Code of the Russian Federation include:

• individuals who, at the time of the beginning of participation in a foreign organization, are actually in the Russian Federation for at least 183 calendar days within 12 consecutive months;
• all Russian organizations;
• foreign organizations, the place of actual management of which is the Russian Federation (exceptions may be established by an international treaty);
• foreign organizations permanently located in states with which the Russian Federation has valid international treaties on taxation issues, operating in the Russian Federation through separate subdivisions and independently recognizing themselves as tax residents of the Russian Federation.

Thus, individuals who are tax residents of the Russian Federation, regardless of whether they are individual entrepreneurs or not, must send appropriate notifications.

What kind of participation in foreign organizations should be reported to the tax authority, if such participation arose before the adoption of amendments to the Tax Code of the Russian Federation and continues at the present time?
In accordance with clauses 1 and 4 of Article 4 of Federal Law No. 376-FZ of November 24, 2014, a notice of earlier participation in foreign organizations is submitted as of May 15, 2015. The deadline for submitting a notification of such a fate is June 15, 2015.

In this case, the basis for submitting the notification is the excess of the participation share of 10% (subparagraph 1 of paragraph 3.1 of Article 23 of the Tax Code of the Russian Federation).
Taking into account the systemic interpretation, a notification of participation in foreign organizations is subject to submission if, as of May 15, 2015, the share of such participation is more than 10%.
So, by June 16, 2015, persons recognized as tax residents of the Russian Federation as of May 15, 2015 must submit a notification of their existing participation in foreign organizations as of May 15, 2015 (if the share of such participation is more than 10%).

Is there a duty to notify about foreign structures without a legal entity that were established before 2015?
Article 25.14 of the Tax Code of the Russian Federation is devoted to the notification of participation in foreign organizations. By itself, a notice of participation in foreign organizations is the name of the document. This document also reflects information on the establishment of a foreign structure without forming a legal entity (paragraph 5 of Article 25.14 of the Tax Code of the Russian Federation).
Thus, by June 16, 2015, the obligation to notify the tax authorities must be fulfilled:

About established foreign structures without the formation of a legal entity, existing as of May 15, 2015;
- on control over such structures or on the actual right to income received by such structures (fund, partnership, partnership, trust, other form of collective investment or trust management), existing as of May 15, 2015.

Is it required to submit a notification to the tax authority if participation in foreign organizations is terminated?
Notification of a previously arisen participation in a foreign organization shall not be submitted if the obligation to send such a notification to the tax authorities arose after the participation in the foreign organization ceased (the corresponding shares, shares in the authorized capital were sold).
Consequently, the notification is not submitted if, by June 14, 2015 inclusive, participation in a foreign organization is terminated or the established foreign structure without forming a legal entity is liquidated (Part 4 of Article 4 of Federal Law No. 376-FZ of 24.11.2014 (as revised on 06.04.2015 No. 85-FZ)).

Do I need to report to the tax authority about participation in foreign organizations if such participation arose in December 2015 and the size of the participation share is 5%?
According to subparagraph 2 of paragraph 2 of Article 23 of the Tax Code of the Russian Federation (as amended until 2015), taxpayers - organizations and individual entrepreneurs were required to report to the tax authority, respectively, at the location of the organization, place of residence of an individual entrepreneur about all cases of participation in foreign organizations - on time no later than one month from the date of the beginning of such participation.
Clause 3.1. Article 23 of the Tax Code of the Russian Federation introduced a new obligation - to send notifications if the share of participation in a foreign organization exceeds 10%.
Thus, if participation in a foreign organization arose in December 2014 and the size of the participation interest is less than 10%, it is not necessary to inform or notify the tax authority about such participation.

Should the tax authority be notified of participation in foreign organizations that arose before 2015, if the share of such participation has not changed?
Since 2015, the obligation to send messages about participation in a foreign organization has been canceled.
By order of the Federal Tax Service of Russia dated 09.06.2011 No. ММВ-7-6 / [email protected] form No. С-09-2 "Notification of participation in Russian and foreign organizations" was approved, which provides fields for indicating the beginning of participation, making changes on the share of participation.
The Tax Code of the Russian Federation provides for a new document - a notification of participation in foreign organizations and introduces special responsibility for failure to provide such a notification.
On the basis of clause 2 of Article 129.6 of the Tax Code of the Russian Federation, the unlawful failure by the taxpayer to submit to the tax authority a notice of participation in foreign organizations or the submission of a notice of participation in foreign organizations containing inaccurate information, entails a fine of 50,000 rubles in respect of each foreign organization, information about which is not provided or in relation to which false information is provided.
Thus, a notification of participation in foreign organizations (with a participation share of more than 10%) must be sent to the tax authorities, including if, before 2015, the organization sent to the tax authority a notification of participation in a foreign organization and a share of participation in a foreign organization for the entire time of ownership did not change.

How to determine the date of occurrence of the basis for notification of participation in a foreign organization that arose before May 16, 2015?
Part 4 of Article 4 of the Federal Law of November 24, 2014 No. 376-FZ (as amended on April 6, 2015 No. 85-FZ), May 15, 2015 is indicated as the date from which the one-month period for sending a notification is counted. It is this date that can be taken as the date of occurrence of the basis for the presentation of the notification (the date of occurrence of participation).

- What are the terms for sending notifications about the beginning of new participation in foreign organizations?
On the basis of clause 3 of Article 25.14 of the Tax Code of the Russian Federation, a notification of participation in a foreign organization is submitted no later than one month from the date of occurrence (change in the share) of participation in a foreign organization, which is the basis for submitting a notification.
In this case, in case of termination of participation in a foreign organization, the taxpayer informs the tax authority about this no later than one month from the date of termination of participation.
The deadline for sending notifications about participation in foreign companies, which occurs from May 16, is one month. Moreover, the provisions on the monthly period for sending notifications come into force on June 15, 2015 (part 3 of article 4 of the Federal Law of November 24, 2014 No. 376-FZ (as amended by No. 85-FZ of April 6, 2015).
That is, the acquisition of 10% (or more) of a stake in a foreign company on May 16, 2015 must be reported no later than June 16.

- How long does it take to notify about the establishment of foreign structures without forming a legal entity?
Tax residents of the Russian Federation are required to notify the tax authority about the establishment of foreign structures without forming a legal entity.
At the same time, the concepts of “foreign organization” and “foreign structure without forming a legal entity” of the RF Tax Code differ (Article 11 of the RF Tax Code).
In the cases necessary, in the opinion of the legislator, the concepts of "foreign organization" and "foreign structure without the formation of a legal entity" are used, in fact, in the same meaning (mainly to denote the possibility of recognition of a foreign organization and a foreign structure without the formation of a legal entity by a controlled foreign company - for example, clauses 2, 3, 6, 8, 9 of Article 25.13 of the Tax Code of the Russian Federation).
In other cases, the concepts of “foreign organization” and “foreign structure without forming a legal entity” are used separately (for example, paragraph 1 of Article 25.15 of the Tax Code of the Russian Federation), or only the concept of “foreign organization” is used (for example, paragraph 3 of Article 25.14 of the Tax Code of the Russian Federation).
The term for sending the notification is established by paragraph 3 of Article 25.14 of the Tax Code of the Russian Federation only in relation to participation in foreign organizations: within a month from the date of occurrence (change in the share) of participation in such a foreign organization.
The time period for notification of the establishment of foreign structures without the formation of a legal entity, established from May 16, 2015, or of control over such structures or of the actual right to income received by such structures that arose from that date, is not established by the Tax Code of the Russian Federation. It turns out that the notification should be sent before the tax authority makes a decision on bringing to responsibility.

- How should you fill out and send a notice of participation in foreign organizations?
The forms, formats, the procedure for filling out and the procedure for submitting notifications must be established by the Federal Tax Service of Russia. The notification must contain the information specified in paragraph 5 of Article 25.14 of the Tax Code of the Russian Federation. Participation in a foreign organization can be direct, indirect, mixed (shares of direct and indirect participation are added). If participation is realized through other persons, then in order to fill out the notification, you will need to assign a unique participant number to each corresponding foreign organization (IE), Russian organization (RO), foreign structure without forming a legal entity (IS).
In the case of indirect participation, when filling out the notification, all sequences (groups) of participation established in accordance with Article 105.2 of the Tax Code of the Russian Federation, which must end with the desired foreign organization, must be provided. The share of participation is calculated by multiplying the percentages of participation in each sequence and adding the resulting shares of participation for all groups.

What happens if the taxpayer does not wait for the order to be released or, for example, has already sent such a notification in any form?
Before the amendments were made, most taxpayers turned out to be violators - they did not submit a notice by the originally set deadline - until April 2. The main reason for the non-submission was the lack of an approved notification form.
On April 7, Federal Law No. 85-FZ of April 6, 2015 entered into force, which postponed the deadline for submitting notifications to June 15.
Thus, there is no reason to consider failure to submit notifications for the period from April 2 to April 7 as delayed. Article 3 of Federal Law No. 85-FZ of April 6, 2015 ruled out even the theoretical possibility of bringing a taxpayer to responsibility under paragraph 2 of Article 129.6 of the Tax Code of the Russian Federation for acts that should have been committed by sending notifications in the period from January 1 to April 7, 2015.
However, the absence of an approved form of the document does not in itself abolish the fulfillment of the obligation to submit it.
It should be noted that no liability has been established for failure to comply with the form and method of submitting a notification to the Tax Code of the Russian Federation.
If the Federal Tax Service of Russia does not timely approve the form (format) of the notification of participation in foreign organizations, the taxpayer may send the said notification in writing in any form.
A taxpayer who has fulfilled the obligation to send a notification cannot be re-involved in the performance of the same obligation.

Is it necessary to send a notification about the change in the share of participation in foreign organizations, if subsequently the size of the share of such participation, for example, is reduced from 30% to 25% or, conversely, from 10% to 30%?
The basis for submitting the notification is the excess of the participation share of 10% (subparagraph 1 of paragraph 3.1 of Article 23 of the Tax Code of the Russian Federation).
If, after the submission of a notice of participation in foreign organizations, the grounds for submitting such a notice have not changed, no further notice shall be submitted.
It can be concluded that in relation to the notification of participation, the amount of which has exceeded 10%, subsequent notifications of changes in participation (increase or decrease), as a result of which the proportion does not fall below 10%, are repeated and should not be submitted.
If the share of participation in the organization was initially 5% and then increased to 10%, then the notification of participation in such a foreign organization shall be submitted no later than one month from the date of the change in the share.

The Federal Law "On Amendments to Parts One and Two of the Tax Code of the Russian Federation (in terms of taxation of profits of controlled foreign companies and income of foreign organizations)" dated November 24, 2014 No. 376-FZ came into force. At the stage of its development and discussion, the law received the unofficial name "anti-offshore bill", "law on deoffshorization" or "law on controlled foreign companies (CFC)".

According to the changes made to the Tax Code (chapter 3.4, article 25.14), taxpayers recognized as tax residents of the Russian Federation are required to notify the tax authorities:

1. On their participation in foreign organizations (if the share of such participation exceeds 10%), on the establishment of foreign structures without forming a legal entity.
   Must be submitted on time no later than 3 months from the date of occurrence or change of the share participation in such an organization.
2. Controlled foreign companies of which you are controlling.
   Notification of controlled foreign companies must be submitted on time no later than March 20 of the year following the tax period in which the share of the profits of the controlled foreign company is subject to accounting with the controlling person.

Thus, when creating a foreign company, a Notice of Participation is first submitted, which discloses information about the owner, the order of ownership of the company and the share of participation, and then every year, by March 20, a Notice of CFC is submitted, which reflects information about the order of ownership, and share of ownership, on the availability of financial statements of the company, an auditor's report.

Example: An individual became a 100% shareholder of the company in the BVI on 02/01/2018.

1. Within 3 months from 02/01/2018, an individual must submit a Notification of participation in a foreign company in the approved format to his territorial office.
   • To prepare a notification, you will need corporate documents of the company.
2. If the company's profit for 2018 was not distributed, and the decision on the distribution of such profit was not made, then the profit of a controlled foreign company at the end of 2018 is recorded with an individual on December 31, 2019.
3. By 20.03.2020, an individual must submit a CFC Notice for 2019 based on profits in 2018 to his territorial office.
   To draw up the 2019 CFC Notice, you will need the following information:
   • Corporate documents of the company
   • Financial statements for the corresponding year in accordance with IFRS standards (or in accordance with approved local reporting standards), if the company does not prepare statements in accordance with Chapter 25 of the Tax Code of the Russian Federation "Income Tax"
   • Auditor's report on these statements

Our services:

• Consultations on the need to submit a notification - 8,000 rubles per hour.
• Notification of participation in a CFC (for one company) - 20,000 rubles.
• Notification of termination of participation in a CFC (per company) - 20,000 rubles. If the Notification of participation in a CFC was drawn up through our company, then the cost is 10,000 rubles. for company.
• CFC notification - RUB 25,000 one company each + 15,000 rubles. for an additional year for the same company.
• Submission of a notification to the tax office (optional) - 2,000 rubles. + notarization of the power of attorney.
• Analysis of documents of a foreign company to establish the continuity of the chain of ownership, missing documents, errors in them, etc. (if necessary) - from 70,000 rubles.

Latest trends

In 2018-2019, more and more requests are received from the tax authorities of the city of Moscow regarding the provision of Notices of participation in a foreign company, as well as Notices of CFCs. But there have also been separate inquiries, in which the tax authorities do not limit themselves to providing only Notifications, but require the submission of CFC statements, an auditor's report, and tax registers.

The tax authority in the Chelyabinsk region sends information letters to the owners of CFCs about the deadlines for submitting CFC notifications. After submission of the CFC Notices, the tax office requests reports with translation and explanations. All the work of a tax inspector for a CFC is under the control of the regional Directorate of the Federal Tax Service of Russia for the subject. The inspector is in close contact with representatives of the Federal Tax Service and the declarant on the submitted reports. The Tax Inspectorate offered to declare the trust agreement as a foreign structure, but after providing written explanations, it waived its claims.

Penalties for Failure to Provide Notice

• In case of failure to submit a notification about a controlled foreign company or providing false information in the notification, a fine of 100 thousand rubles is provided. (Clause 1 of Article 129 of the Tax Code).
• For failure to submit a notice of participation or the provision of false information in the notice, a fine of 50 thousand rubles is provided. (Clause 2 of Article 129 of the Tax Code).

Partner

On January 1, 2015, as part of the fight against offshore companies in Russia, the so-called “deoffshorization” amendments to the Tax Code of the Russian Federation came into force. Below is a set of actions that must be taken by an individual if he has registered or bought shares of a foreign company.

In relation to the controlling person of a tax resident of the Russian Federation - a taxpayer - an individual

> Preparation and submission of CFC notifications

Submission of Notice of Participation in Foreign Organizations and Notice of Controlled Foreign Companies (CFC)

In accordance with Article 25.14 of the Tax Code of the Russian Federation tax residents of the Russian Federation - INDIVIDUALS AND LEGAL ENTITIES - are obliged to notify the tax authority at the place place of residence or place location of the organization, respectively:

1) about your participation in foreign organizations (on the establishment of foreign structures without forming a legal entity);
2) about controlled foreign companies of which they are controlling.

These are TWO different types of Notices that must be filed (or may not be filed subject to certain conditions, which will be discussed below) with the tax authority to a person who owns a foreign company.

Let's consider both options sequentially.

In accordance with clause 1, clause 3.1. Article 23 of the Tax Code of the Russian Federation, the taxpayer is obliged to notify the tax authority of both direct and indirect participation in foreign organizations if the share of such participation exceeds 10%... At the same time, the share of indirect participation in a foreign organization is determined in accordance with the procedure established by Art. 105.2 of the Tax Code of the Russian Federation.

It is also necessary to notify about participation in foreign organizations if participation in them is carried out through nominees.

Example.
You are the beneficiary of a Cyprus company - you are not a director or shareholder, you are the beneficiary whose rights to the company arise from a declaration of trust - the law nevertheless requires you to file a Notice as the person controlling the company. At the same time, “control” means the right to influence the decision on the distribution of the company's profits.

The obligation to notify also lies with taxpayers who have established the so-called ISBOYL - a foreign structure without a legal entity (these include, among other things, current British LLPs and Scottish LP partnerships). In accordance with Clause 2 of Article 11 of the Tax Code of the Russian Federation ISBOYL means an organizational form created in accordance with the legislation of a foreign state (territory) without forming a legal entity (in particular, fund, partnership, partnership, trust, another form of collective investment and (or) trust management), which, in accordance with its personal law, has the right to carry out activities, aimed at generating income(arrived) in the interest of its participants (shareholders, trustees or other persons) or other beneficiaries.

Deadline for filing a notification

In accordance with paragraph 3 of Art. 25.14 of the Tax Code of the Russian Federation:

Notification of participation in foreign organizations (on the establishment of foreign structures without forming a legal entity) is submitted no later than three months from the date of occurrence (change in the share) of participation in such a foreign organization (the date of establishment of a foreign structure without forming a legal entity), which is the basis for submitting such a notification.

Procedure and form of notification

Forms of notification of participation in foreign organizations approved By order of the Federal Tax Service of the Russian Federation dated April 24, 2015 No. ММВ-7-14 / [email protected]- applied until August 12, 2019 and the Order of the Federal Tax Service of Russia dated July 05, 2019 N ММВ-7-13 / [email protected]- applies AFTER August 12, 2019. Please note that:

• legal entities must send notification exclusively in electronic form, only via telecommunication channels (TCS) and only in the presence of an enhanced qualified electronic signature (UKEP) *
• individuals have the right to submit a notification on paper

In case of incomplete information, inaccuracies or errors in filling out the submitted CFC notification, the taxpayer is also entitled on the basis ofClause 7 of Article 25.14 of the Tax Code of the Russian Federationsubmit to the tax authorityupdated notice.
In the case of submission of a revised notification before the time when the taxpayer learned about the establishment by the tax authority of the fact that inaccurate information was reflected in the notification, the taxpayer exempt from liability provided for in Article 129.6 of this Code.

What documents are required?

There are no legal requirements for the mandatory attachment of documents to the CFC Notice. However, one of the sheets of the Notice must contain information about the date of preparation of the financial statements and the date of the auditor's report.

From which we can conclude that it should be prepared in any case without fail, either in accordance with local law and the standard for the preparation of financial statements, or according to.

AUDIT must be carried out (even if it is NOT mandatory) in the event that the Notice is filed in relation to the fact of ownership of a foreign company with which Russia does not have an agreement on the exchange of tax information.At the same time, the auditor's report should not contain a negative opinion.

Example.
It is NOT required to audit financial statements for, European jurisdictions and others, since Russia has agreements on the avoidance of double taxation concluded with them.
It is REQUIRED to conduct a voluntary audit for all offshore companies:, etc.

After preparing the reports and conducting the audit and submitting the Notice, you must be prepared for the fact that the employees of the Federal Tax Service "within the framework of clarifying the information stated in the Notice" will request to provide documents confirming the declared information. After the receipt of these requirements, the FTS will need to provide translated copies of the financial statements and the auditor's report (there are no requirements for an apostille and notarization of the translation). As practice shows, after the submission of these documents, questions from the Federal Tax Service are no longer received.

Responsibility for Late Submission of a CFC Notice

In accordance with Clause 1 of Article 129.6 of the Tax Code of the Russian Federation

Unlawful failure to submit to the established term by the controlling person to the tax authority a notification of controlled foreign companies for a calendar year or the submission by the controlling person to the tax authority of a notification of controlled foreign companies containing inaccurate information,

entails a penalty a fine of 100,000 rubles for each controlled foreign company, information about which is not provided or in relation to which false information has been provided.

That is, if a taxpayer who has registered a foreign company with 100% participation does not send TWO notifications to the tax authority (as required by the new rules), then he will be liable in the form of a fine of 150,000 rubles. (50,000 rubles + 100,000 rubles).

The cost of our services

* Depending on the complexity of the corporate structure. The indicated cost includes an analysis of the ownership structure, as well as oral consultations related to the CFC

The need to form a notification of participation in foreign organizations appeared relatively recently - from January 2015. For a number of persons, this document is mandatory, while its preparation takes place in a certain form of U-IO.

Files

Who is required to file a notice

This document must be submitted by:

• citizens of Russia;
• persons with dual citizenship;
• those who do not have citizenship at all;
• enterprises and organizations.

In addition, the responsibility for the formation of the document lies with some foreign companies, including those that have subdivisions and branches within the Russian Federation and are considered, accordingly, taxpayers of our country.

The reason for filing a notification is both joining the members of a foreign organization and leaving it. When "reformatting" shares, you should also notify the regulatory authorities.

Where and in what time frame to transfer the document

The notification is submitted to the local territorial office of the tax service, no later than thirty days (according to the calendar) from the date of "entry", change of share or "exit" from a foreign organization.

Refusal to accept a document

Sometimes the tax authorities may refuse to accept the submitted documents. In this case, notification of participation in foreign organizations is no exception. True, the list of reasons for refusal is not so long:

• incorrectly completed form;
• failure to provide originals of accompanying documents;
• poor copy quality.

To correct the situation, you need to correct all the shortcomings and reapply.

And if you do not submit a notification

Failure to comply with the obligation to transmit a notice of participation in foreign organizations can lead to serious consequences in the form of a fairly large fine (up to several tens of thousands of rubles).

At the same time, it should be remembered that the purposeful concealment of this fact will not end well either, since today tax authorities have access to various sources of information (including assistance with the tax services of other states in terms of information exchange).

Rules for filling out the notification

If you need to generate and send to the tax office a notice of participation in foreign organizations, we recommend using the advice below and see a sample of how to fill out the document.

To begin with, let us recall that the notification form has a unified look and is required for use.

1. You can enter information into the form either by hand (but only with a blue, black or purple ballpoint pen) or in printed form on a computer.
2. Words should be written in large capital letters, legibly, so that it is readable and understandable.
3. Make mistakes in the form, you cannot make blots. If the mistake did happen, you should not correct it, it is better to fill out another form. And, of course, it is forbidden to indicate deliberately false information in the notification - if such facts are discovered, the consequences can be the most unpleasant.

If, after the notification has been sent, the taxpayer suddenly discovers that there was some inaccuracy in it, he has the right to submit an updated notification - no sanctions are provided for this, the main thing is to meet the deadlines.

Sample filling out a notification on participation in foreign organizations

Filling in the first sheet

On the first page at the top of the notification, data about the taxpayer is entered: the details of the company, its full name (with a decrypted organizational and legal status). The number of the correction, the code of the tax authority and the taxpayer code, the reason for the formation of the document are also indicated here.

The bottom of the page is divided into two sections. In the left one, you first need to indicate the code of the notifier (the decryption is given right there), then enter his personal and contact information, sign and fill out the date.

Filling in the second sheet

The second page of the notification is filled out if the speech is on behalf of an individual. At the same time, as mentioned above, it does not matter whether he is a citizen of only the Russian Federation, has dual citizenship, or none at all. All information entered here must correspond to a passport or other identity document. If the notifier leaves this page blank, he must still put his signature and date under it (the same applies to other pages of the document).

Completing the third sheet

The third page contains information about the foreign organization in question. First, you need to enter its name here, and in Russian and English.

Below is the country code, company registration number and address of its actual location, other known data. Then it should be noted what relation the notifier has to the organization: direct, indirect, or both, date, month, year of participation, share and end date (the latter - if the document is submitted in connection with the exit from the organization).

Completing the fourth sheet

The fourth page includes information about a Russian company participating in a foreign organization. The information entered here must be identical to the incorporation papers of the company.

Filling in the fifth sheet

The fifth page contains data on participation in a foreign structure without the formation of a legal entity. person (i.e. partnership, foundation, trust, partnership, etc.).

Completing the sixth sheet

The sixth page indicates the status of a participant in a foreign structure without the formation of a legal entity. person (i.e. who the applicant is: the founder of such a company, the recipient of the income or the controlling entity).

Completing the seventh sheet

Finally, the last - the seventh page - reveals the procedure for the indirect participation of the notifier in a foreign company: here all links in the chain of which the foreign organization belongs, in which, in turn, the notifier participates, is indicated, as well as the serial number of his participation and his share.

How to send a notification

To send a notification to the tax office, you can use one of several options:

1. The most reliable and simple one is to take the completed form to the tax office personally and hand it over to a specialist.
2. You can forward the notification with a representative, provided, of course, that he has a power of attorney certified by a notary office.
3. And one more way: to send the document by registered mail with acknowledgment of receipt via regular mail - this will take more time, but it guarantees that the notice will be received by the tax authorities.