Arguable order of registration of insurants with Pension Fund of the Russian Federation
Evgeny Voronov, Lawyer
Foreign organizations having their branches and representative offices accredited in 2017 are experiencing some difficulties when applying for register with the Pension Fund of the Russian Federation (hereinafter – «PFR») – they cannot obtain an insurant number. According to paragraph 10 Article 21 of the Federal Law of 09.07.1999 № 160-FZ «On foreign investments in the Russian Federation», from January 1, 2015 Federal Tax Service (hereinafter – «FTS») is being obliged to submit electronic data of branches and representative offices to the non-budgetary funds, including the PFR, within three working days from the day of accreditation to register them as insurants.
In practice, FTS has never been submitting this data. Until 2017, foreign organizations were free to apply for registration with the PFR bringing there an application and a full package of documents of a company and its accredited branch or representative office. However, from the 1st of January, 2017 the PFR does not accept any documents from applicants. Thus, new accredited branches of foreign companies cannot obtain registry numbers from the PFR. Having their branches not registered, foreign companies are not able to submit accounting reports, that may lead to the sanctions imposed by the state authorities.
To avoid negative consequences, it is strongly recommended to submit reports to the PFR not even having an insurant number (but to write a null instead of this number; taxpayer identification number, tax registration reason code and other details to be specified in accordance with the documents received from FTS). It is also desirable to obtain a document from the PFR that would verify the fact of applying to the PFR and getting a refusal. When the data system of the PFR and FTS starts functioning, registration of a foreign company with the PFR will be processed automatically.
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Evgeny Voronov, Lawyer
Foreign organizations having their branches and representative offices accredited in 2017 are experiencing some difficulties when applying for register with the Pension Fund of the Russian Federation (hereinafter – «PFR») – they cannot obtain an insurant number. According to paragraph 10 Article 21 of the Federal Law of 09.07.1999 № 160-FZ «On foreign investments in the Russian Federation», from January 1, 2015 Federal Tax Service (hereinafter – «FTS») is being obliged to submit electronic data of branches and representative offices to the non-budgetary funds, including the PFR, within three working days from the day of accreditation to register them as insurants.
In practice, FTS has never been submitting this data. Until 2017, foreign organizations were free to apply for registration with the PFR bringing there an application and a full package of documents of a company and its accredited branch or representative office. However, from the 1st of January, 2017 the PFR does not accept any documents from applicants. Thus, new accredited branches of foreign companies cannot obtain registry numbers from the PFR. Having their branches not registered, foreign companies are not able to submit accounting reports, that may lead to the sanctions imposed by the state authorities.
To avoid negative consequences, it is strongly recommended to submit reports to the PFR not even having an insurant number (but to write a null instead of this number; taxpayer identification number, tax registration reason code and other details to be specified in accordance with the documents received from FTS). It is also desirable to obtain a document from the PFR that would verify the fact of applying to the PFR and getting a refusal. When the data system of the PFR and FTS starts functioning, registration of a foreign company with the PFR will be processed automatically.