Published 17 September 2026, Synergy Audit
The Federal Tax Service steps up scrutiny of closed-end unit investment funds
The Federal Tax Service is stepping up its scrutiny of the use of closed-end unit investment funds (closed-end UIFs) for unlawful tax optimisation.
The tax authorities analyse transactions with such funds, paying particular attention to:
- whether there is genuine investment activity;
- who actually controls the assets;
- who obtains the economic benefit from transactions through the fund.
Conclusion
Using closed-end UIFs mainly to obtain tax savings, while the former owners retain control over the assets and the economic benefit, is an area of heightened attention for the Federal Tax Service.
Companies that use closed-end UIFs should check that the structure has a business and investment purpose and that this purpose is documented.
Source: meeting of the Expert Council under the Federal Tax Service of Russia on 10 September 2026
Cover of the post in the Synergy Audit Telegram channel
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