Federal law #312-FZ from 12-30-2008 entitled “On Introducing Changes to Part One of the Russian Federation’s Civil Code and Other Legislative Acts” went into force July 1, 2009. According to the law on regulations of OOOs established before the law came into force, they are required to be in compliance with the new regulations no later than January 1, 2010. Information about this can be found on the Moscow Administration of the Federal Tax Service’s (MAFTS) website.
However, the Moscow tax authorities note that neither Federal Law #312-FZ nor any other legislative acts have provisions for penalizing or shutting down businesses that have not re-registered by January 1, 2010 or for automatically excluding them from the Unified State Register of Legal Entities.
The deadline for turning in re-registration documents may be extended beyond January 1, 2010.
The MAFTS reports that, currently, re-registration is necessary only for those organizations whose capital stock is less than the 10,000 ruble legal minimum established by law and for those OOOs whose stockholders are planning to divest their shares in the near future.
In the interest of saving company owners’ time, the Moscow tax authorities recommend taking advantage of the opportunity to send documents by mail (in an insured package with a list of contents enclosed) to the registering department of the Interdistrict Federal Tax Inspectorate #46 at: Pokhodny St. Complex 3, Building 1, Moscow, 125373; or submit documents via a representative possessing power of attorney to the registering department at: Pokhodny St. Complex 3, Building 4, window #10, which receives documents from third parties.
However, the President of the Association of Russian Banks, G. Tosunyan, was not as optimistic as the tax authorities on this in his addresses to the media. He said that banks (due to their procedural regulations) will not be able to provide services to organizations that have not re-registered, since they themselves may face sanctions from the tax authorities.
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