Russia’s FNS deletes 4,000 technical companies from VAT systems as paper VAT cleanup moves into enforcement mode

The Russian tax service, FNS, has removed 4,000 legal entities from its systems after sending the list to the прокуратура (prosecutor’s office) and receiving a response back. For high-risk payment and tax-sensitive businesses, the detail that matters is simple: this is not a paper exercise anymore, and companies using technical entities to support VAT schemes now face a more direct path to reassessments, fines, penalties, and criminal cases.

1. The FNS built the list of 4,000 legal entities using control ratios (control’nye sootnosheniya, or k/s) — a section handled only by the tax service’s control and analytics department. According to the source, tax officers did not check other parts of the system when compiling the list: not trees, not SURs, not comments, nothing else.
2. After the list went to the prosecutor’s office, the FNS removed all 4,000 legal entities from the AIS and AСК НДС systems. The source says this was not a withdrawal of electronic signatures and not a quarterly reporting reset. In practice, if you enter the company’s TIN in the program now, you see nothing — just an empty record.
3. Platforms cannot restore the reporting for these legal entities. Anyone who bought paper VAT directly from one of the 4,000 companies will receive additional tax assessments, with fines, penalties, and criminal cases attached. That is the enforcement path the source describes, not a theoretical risk.
4. This was the first such move by the FNS. More than half of the technical legal entities on the list had already been liquidated, and limitation periods for additional assessments had already expired for many of them. The FNS is now preparing new lists and intends to do this systematically.
5. The source says the standard defense from platforms — that everything is fine if there are no signs in SUR and no breaks in the tree — does not help here, because the FNS is not looking at SUR or tree structures at all. It is looking only at k/s. New technical companies will also be caught later, with the same sequence: request to the prosecutor’s office, response, deletion from AIS.

For high-risk operators, the operational takeaway is not subtle: if a model depends on replenishing technical entities to support VAT chains, the state side is now treating the cleanup as a repeatable process, not a one-off raid. The source also notes a structural problem for platforms: they cannot grow their technical entity pool as fast as the FNS is deleting companies, while the “safe” volume of the cover on one technical entity is falling each year.