Alexey Stanchin, Head of Tax Compliance Practice, in the publication «Company Lawyer» reminded about important tax changes that have already come into force in 2025.

Since January 1, companies have the right to appeal against decisions of the Federal Tax Service and actions of its employees in a simplified procedure. The tax authority will have seven days to consider the appeal. The decision will be made by the same inspectorate whose actions are being challenged. It has no right to leave the complaint without consideration. If it does not satisfy it in whole or in part, it will send it to a higher authority to be considered by the latter in the general order.

It is up to the company to decide whether to consider the complaint in the general or simplified procedure. However, it will not always be possible to choose the simplified procedure. Decisions on the results of audits and cases of tax offenses can still be appealed only in the general order. Simplified will be suitable, for example, for disputes about blocking the account or overpayments. To be considered in the simplified procedure, it will be necessary to submit an electronic complaint via TCS or through the personal cabinet of the taxpayer.

The compulsory pre-trial procedure has also been extended. It now also applies to disputes of a property nature. Namely, those which have resulted from a non-normative act of an inspectorate, actions or inaction by its officials. For example, if you demand from the tax office to return illegally collected taxes, penalties and fines, interest for late unblocking of accounts, recognize collection orders as unenforceable. In respect of these disputes, the company will first have to file a complaint. If it decides to go straight to court, it will return the statement of claim or leave it without consideration. 

The expert reminded that a multi-stage progressive scale for personal income tax payers has been launched. The changes affect all those who pay personal income tax independently or through tax agents. From 2025, the scale became multi-stage - from 13 to 22%.

Payments under labor and civil law contracts will be taxed at the following rates:

• income up to 2.4 million rubles - 13%;
• income from RUB 2.4 million to RUB 5 million - 15%;
• income from RUB 5 million to RUB 20 million - 18%;
• income from RUB 20 million to RUB 50 million - 20%;
• income exceeding RUB 50 million - 22%.