In September 2025, Moscow Digital School hosted a lecture “Jurisdictional Aspects of E-Commerce.” During the event, Kirill Chernovol, Researcher at the Gaidar Institute's International Best Practices Analysis Department, spoke about the current situation of international taxation in e-commerce, the global minimum tax being introduced by countries for international companies, and the problems of currency control under sanctions.
Large transnational corporations, primarily “digital giants,” are now seeking to pay less tax, including by fragmenting their businesses and shifting profits out of the tax base. To prevent this, countries have agreed to introduce a minimum income tax of 15%. More than 50 countries have already done so, and Russia has drafted amendments to its Tax Code.
Kirill Chernovol drew attention to the problem of mandatory repatriation of export proceeds under currency control: funds “stuck” in exporters' foreign accounts must be credited to an account in a Russian bank within 45 days. Otherwise, the company risks a fine of 20-40% of the amount of unrecovered funds. To avoid this, it is necessary to prove to the Federal Tax Service that all possible measures have been taken to recover the money: correspondence with banks and counterparties, appeals to diplomatic missions, lawsuits, and other actions.