Business Splitting Is Dead: What to Do When Revenue Hits 20M

From 1 January 2026, the VAT-free threshold for companies on Russia’s simplified tax system (USN) dropped from 60 to 20 million roubles. The Federal Tax Service has signalled that the limits will keep falling: to 15 million in 2027 and 10 million in 2028.

For most business owners whose revenue is approaching this mark, the first thought is: “I’ll open a second company under my partner’s, spouse’s, or accountant’s name and split the cash flows.”

Stop. In 2026, that move is a direct path to a tax audit.

Why business splitting no longer works

The ASK-VAT automated control system has become significantly more capable in recent years. It automatically cross-references the data of all legal entities and sole traders and flags signs of artificial splitting.

What the tax authority sees:

  • Two or more legal entities accessing their taxpayer accounts from the same IP address
  • Shared contractors working with both “separate” companies
  • A single website or phone number used by different legal entities
  • Overlapping staff — the same employees appearing in multiple companies
  • The same registered or actual business address
  • Money moving between entities without real contracts underlying the transfers

If several of these signs are present, the Federal Tax Service classifies the structure as artificial business splitting. The result: tax reassessment for the full period at the 22% rate, plus penalties and a fine of 40% of the underpaid amount (Art. 122 of the Tax Code, classified as an intentional violation).

How to divide a business legally

Restructuring a business into separate entities is possible — but only if each entity has a real business purpose beyond the desire to stay below the tax threshold.

Signs of a legitimate split

Independence of each entity:

  • Its own director with real authority
  • A separate staff that does not overlap with other group companies
  • Its own assets, premises, and supplier contracts

Different lines of activity:

  • Manufacturing separate from retail, logistics separate from service delivery
  • Not just duplicating the same service under two names

Separated accounting and management:

  • No shared cash pools, no money transferred without underlying contracts
  • Each entity has its own profit, its own costs, its own reporting

A transparent business rationale:

  • Why this particular split? The explanation must extend beyond tax reasons.

What will not protect you

  • Registering a second company under a nominal director
  • Transferring the same clients to the “new” entity without real separation of functions
  • Shared bank accounts, a single accountant, or one accounting system
  • Moving employees “for appearances” while keeping unified management

What to do now

If your revenue is approaching 20 million roubles:

  1. Do not wait — restructuring must happen before the threshold is crossed, not after.
  2. Review your current structure — if you already have multiple legal entities, verify that each meets the independence criteria.
  3. Document the business rationale — in board minutes, strategy documents, and operational records.
  4. Separate your accounting — bank accounts, bookkeeping systems, HR records.

If you are uncertain whether your current structure is defensible, it is better to find out now than to explain it to a tax inspector later.

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