Since January 1, 2026, amendments have been fixed in the Tax Code of the Russian Federation, significantly expanding the powers of the Federal Tax Service. Federal Law No. 425-FZ of 11/28/2025 amended Article 11 of the Tax Code of the Russian Federation (clarifying the concept of property), and also applies to the implementation of interim measures under the rules of Article 101 of the Tax Code of the Russian Federation. Now interim measures can be applied not only to things and money, but also to the property rights of the taxpayer, including accounts receivable.
We are talking about the possibility of prohibiting the alienation of such rights in order to enforce decisions of tax authorities.
What has changed
The Tax Code of the Russian Federation clarifies the concept of “property” for the purposes of applying interim measures. It has been brought into line with civil law and now includes:
things and money;
non-cash funds;
property rights, including the rights to demand payment from counterparties (accounts receivable);
other property assets.
In fact, accounts receivable are officially recognized as an object to which the tax authorities have the right to apply interim measures.
What does the Federal Tax Service have the right to do now
The tax authorities have been given the opportunity:
to establish a ban on the alienation of property rights;
limit the disposal of accounts receivable;
use such measures to enforce decisions on additional taxes, penalties and fines.
Previously, such measures were applied only to tangible assets, and accounts receivable were excluded from the list of possible collateral.
Tax risks for businesses
For organizations and entrepreneurs, changes mean:
increased risk of blocking current assets expressed in accounts receivable;
reduced financial flexibility in the presence of tax disputes or debt;
increasing the importance of timely fulfillment of the requirements of the Federal Tax Service.
Even if there are significant amounts to be received from counterparties, the company may be limited in its right to dispose of these claims.
Legal consequences
From a law enforcement perspective, it is expected:
more active use of interim measures by the Federal Tax Service;
strengthening the position of tax authorities in debt collection disputes;
the need for more thorough documentation and control of tax liabilities.
For businesses, the role of preliminary tax analysis, as well as building a protection strategy during inspections, is increasing.
What is recommended for companies
to regularly monitor the presence of arrears and requirements of the Federal Tax Service;
analyze the structure of accounts receivable;
do not delay the settlement of tax disputes;
consider possible limitations in financial planning.
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A source: https://buh-a.ru/o-companii/novosti/11-novosti/370-debitorskaya-zadolzhennost-pod-kontrolem-fns
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