Tax office request about a foreign account: how to reply and which documents to attach

In brief

• After the automatic exchange of financial information, the tax service compares foreign bank data with your notifications, reports and tax return. Where they do not match, you receive a demand or a summons to give explanations.
• Explanations on a 3-NDFL return are due within 5 working days, documents during an audit within 10 working days. The period runs from the day after the day of receipt.
• If you cannot collect the documents in time, you warn the tax office in writing: under Article 93 of the Tax Code, no later than the day after you received the demand.
• You can reply through the taxpayer online account, via telecommunication channels, by registered post or in person. You certify copies yourself; no notary is needed.
• Silence costs RUB 5,000 under Article 129.1 of the Tax Code or RUB 200 per document under Article 126. What costs more is the tax office settling the matter without your explanations.

Which document have you received

The Tax Code has no single form called a "foreign account request". The tax office uses its ordinary control tools, and the first thing to do is find the article cited in the letter. It determines the deadline, the form of the reply and the fine for silence. Where these letters come from and why there were more of them in autumn 2026, we covered in our news item on tax service requests after the 2025 data exchange. Here I focus on how to reply.

Summons notice. Subparagraph 4 of paragraph 1 of Article 31 of the Tax Code allows the tax office to summon a person to give explanations in connection with paying taxes or in other cases related to compliance with tax law. The notice states a date, time and room. You can attend yourself or send a representative with a power of attorney. If you cannot attend, ask the inspector, using the phone number in the letter, whether written explanations can be sent instead of a visit.

Demand for explanations on a return. If you filed a 3-NDFL return and the data from abroad does not match it, the tax office, during a desk audit under paragraph 3 of Article 88 of the Tax Code, reports the error or mismatch and requires you within five days to give explanations or make corrections. A correction means an amended return.

Demand for documents. During an audit the tax office requests documents under Article 93 of the Tax Code, with a 10-day deadline. Outside an audit, if the question concerns a specific transaction, documents and information are requested under paragraph 2 of Article 93.1, also with a 10-day deadline. Refusing or being late with documents is penalised under Article 126, with information under Article 129.1.

Information letter or message in the online account. Sometimes the tax office first simply reminds you to file a report on movement of funds or an account notification. Formally this is not a demand, and there is no deadline or fine for not replying. But it is a signal that the mismatch is already visible, and the next letter will be a demand or an administrative offence report.

What this means for you. First find the article number and the date of posting or dispatch in the letter. Only then plan your reply: you have a week for explanations and two weeks for documents.

How to count the deadline and what to do if you cannot make it

Periods in the Tax Code expressed in days are counted in working days unless calendar days are stated expressly; this is set by paragraph 6 of Article 6.1. The period starts on the day after the event, and if the last day falls on a weekend or public holiday, it moves to the next working day.

The day of receipt is not the day you opened the letter but the day defined by paragraph 4 of Article 31 of the Tax Code. If the document was posted in the taxpayer online account or arrived through the account on the state services portal, it is the day after posting. If it was sent by registered post, it is the sixth day from dispatch. Example: a demand for explanations is posted in the account on Thursday 12 November 2026. It counts as received on 13 November, the first day of the period is Monday 16 November, and the fifth working day is Friday 20 November. The reply must arrive by the end of that day.

If you cannot collect the documents, the Tax Code offers a lawful way out. Under Article 93, the person being audited must, within the day after receiving the demand, notify the tax office in writing that the documents cannot be provided on time, giving the reason and the date by which they will be provided. Under Article 93.1 such a notice is filed within the deadline itself. The tax office may extend the deadline but is not obliged to. For explanations under paragraph 3 of Article 88 there is no separate extension procedure. In that case I would reply on time with what you have and state plainly which documents you will send later and when.

Foreign statements and certificates often take longer than five working days. A bank in Dubai, Istanbul or Yerevan may need a week or more to prepare a letter confirming the account opening date, and a tax residency certificate needs time for an apostille and translation. So ask for an extension under Article 93 straight away, on the first day, not the last.

What this means for you. Missing the day after receiving a demand for documents takes away the simple way to push back the deadline. Open your online account as soon as you get a notice and decide whether you can make it.

How to send the reply: online account, telecom channels, post

Paragraph 2 of Article 93 of the Tax Code lists the methods: in person or through a representative, by registered post, electronically via telecommunication channels or through the taxpayer online account. For most people the online account is the most convenient.

• Taxpayer online account. The reply to a demand and the documents are sent directly from the account, with paper documents attached as scans. Documents are signed with a non-qualified electronic signature issued by the account itself; under Article 11.2 of the Tax Code they are equivalent to documents with a handwritten signature. An acceptance receipt appears in the account.
• Telecommunication channels. Through an electronic document operator with an enhanced qualified electronic signature. This route is more often chosen by sole traders and those replying through a representative.
• Registered post. With a list of contents and acknowledgement of receipt. The deadline is met by the date of dispatch, but the tax office will see the reply later. If you are abroad, a representative in Russia can send the letter.
• In person or through a representative. The second copy of the cover letter with the inspectorate stamp of receipt is your proof. A representative needs a power of attorney issued under the rules of Article 29 of the Tax Code.

Paper documents are filed as copies that you certify yourself: write "true copy", sign, add your name and the date. The tax office may not demand notarised copies; paragraph 2 of Article 93 says so directly. The pages are numbered and bound. I would accompany foreign-language documents with a Russian translation from the outset; it saves an extra round of correspondence. Where the translation must be certified, a sworn or notarised translation will help, and for certificates from other countries an apostille.

What this means for you. Reply through a channel that leaves proof of the date. A receipt from the account, a postal list of contents or a stamp on your copy of the letter will be needed if you later have to argue about deadlines.

What to write in your explanation

Explanations are written in free form. A good explanation is short: the tax office needs facts and documents, not a life story. I recommend this structure:

• Header. The tax inspectorate, your full name and taxpayer number (INN), the number and date of the demand you are replying to.
• The account. Bank, country, account type (current, deposit, brokerage), opening date and, if relevant, closing date.
• What has been filed. The account opening notification, reports on movement of funds, 3-NDFL returns, with filing dates and receipt numbers. If something was not filed, say so and state what you have filed now.
• Residence. If you were abroad for more than 183 days in the year in question, state the number of days in Russia and what proves it.
• Income. What income the account produced: interest, dividends, sale of securities. Whether it was declared and whether tax was withheld abroad.
• List of attachments. Number, document title, number of pages.

What should not be in the explanation. Do not write assumptions ("I think the account is closed"), do not admit to anything you cannot support, and do not explain where the money in the account came from unless you were asked. If the tax office asks about the source of funds, answer with documents: a flat sale agreement, an income statement, a dividend statement. How such a chain is assembled for banks is described on our page on proving the source of funds; the approach for the tax office is the same.

What this means for you. An explanation is a list of facts with evidence. The fewer opinions and the more dates, numbers and receipts it contains, the faster the question is closed.

Which documents to attach

The set of documents depends on exactly what did not match in the tax service database. The basic set is almost always the same: the bank statement for the relevant year showing the opening and closing balance, credits and debits, plus receipts for everything you have filed about the account. The rest depends on the situation.

A word about a tax residency certificate from another country. It is issued by the tax authority of the country where you live: in the UAE, for example, by the country's Federal Tax Authority, and we described the conditions in our article on UAE tax residency. What this document is and where it is needed is explained in our glossary entry on the tax residency certificate. For the Russian tax office the certificate does not settle the matter on its own: Russian residence is determined under Article 207 of the Tax Code as 183 calendar days in Russia within 12 consecutive months. The certificate supports your position, but the days remain the main evidence.

Days are proved with a passport bearing border stamps, tickets and boarding passes, a lease, and documents on work or study abroad. According to its leadership, when residence is in doubt the tax service requests border crossing data from the FSB Border Service, so the figures in your reply must match the real dates. How to count 183 days correctly and the most common mistakes are covered in our article on the 183-day rule and in the glossary entry on the 183-day rule.

What this means for you. If the documents are in a foreign language, allow time for translation, and for official certificates from another country, for an apostille. This is the step that most often makes people miss the deadline.

Five typical situations and how to reply in each

1. The account was not notified. Under Part 2 of Article 12 of Currency Regulation Law No. 173-FZ, a resident informs the tax office of opening, closing or changing the details of a foreign account no later than one month after the event. If there is no notification, file it now, before replying, and attach the receipt. This does not erase the breach: for late filing Part 2 of Article 15.25 of the Administrative Offences Code provides for RUB 1,000-1,500, and for a notification never filed Part 2.1 provides for RUB 4,000-5,000. But a filed notification closes the main question, and what remains is only the size of the fine. How to fill in the notification is shown in our article on notifying the tax office of a foreign account.

2. The report on movement of funds was not filed. The annual report is due by 1 June of the following year. Accounts in EAEU countries and in automatic exchange countries have an exemption: no report is needed if credits and debits for the year did not exceed RUB 600,000. For accounts in countries that do not exchange data with Russia, the report is required whatever the turnover; this includes every EU country, and we wrote about accounts there in our article on an EU bank account without residence. File the report and attach the statement. The fine for being more than 30 days late under Part 6.3 of Article 15.25 is RUB 2,500-3,000.

3. Income was not declared. This is the most expensive situation. A Russian tax resident pays personal income tax on all income, including interest, dividends and gains from selling securities through a foreign broker. The right reply is an amended 3-NDFL return and payment of the tax with late-payment interest. Under paragraph 4 of Article 81 of the Tax Code, you are exempt from the fine if the amended return is filed before you learned that the tax office had found the understatement, and the single tax account already holds the tax and interest. If the demand already names the mismatch, the exemption is hard to rely on. But payment still stops the interest, and the fine for non-payment under Article 122 is 20% of the amount, or 40% if intentional. How the tax on interest and dividends may change, we covered in our news item on the bill raising income tax to 22% on deposits and dividends.

4. You are no longer a tax resident. Under Law No. 173-FZ, the notification and reporting requirements do not apply to residents who spent more than 183 days in total outside Russia during the calendar year. And a non-resident under Article 207 of the Tax Code does not pay Russian tax on foreign income. In your reply, state how many days you were in Russia in the year in question and attach the evidence. Keep the return in mind: if in some year you again spend 183 days or fewer abroad, you must notify the tax office of your accounts by 1 June of the following year, and the reporting obligation starts from that year. What tax residence is and how it changes, we explained in our article on tax residence; for individual countries see our pieces on Turkish residence, Serbia, Georgia and Cyprus.

5. The account belongs to your foreign company. Here the question is no longer about the account but about a controlled foreign company. Individuals file the CFC notification by 30 April, and the fine for not filing is RUB 500,000 per company. What a CFC is and when it arises is explained in our glossary entry on controlled foreign companies, and the changes being discussed for CFCs are covered in our news item on the 2027 tax reform. In this situation I would not reply without a tax adviser.

What this means for you. In the first two situations the reply almost always comes down to a filed document and a small administrative fine. In the third and fifth, tax, interest and large fines are at stake, and the wording of the reply matters.

Fines: what you face and the time limits

Liability for a foreign account arises under two codes. Under the Administrative Offences Code, for breaches of the currency regulation law: notifications and reports. Reports under Article 15.25 are drawn up by the tax office, and the limitation period for currency law breaches under Article 4.5 of that code is two years. Under the Tax Code, for the tax itself and for not replying to demands: Articles 119, 122, 126 and 129.1.

For a repeated breach of the report filing rules, Part 6.5 of Article 15.25 provides for RUB 20,000. We gave a summary table of all obligations and fines in our news item on foreign account requests, so I will not repeat it here. The main point is simple: administrative fines for notifications and reports are small, while tax on undeclared income, interest and a 20% fine are noticeably larger. So close the tax side first and the currency side second.

What this means for you. Replying on time with the documents filed almost always costs less than silence. The tax office cannot "forget" exchange data: if you do not reply, the calculation will be made without your documents.

When it is better to bring in a lawyer

A simple reply you can prepare yourself: the notification was filed, the income was declared, you only need to attach receipts. But there are situations where a mistake in wording costs a lot. I would turn to a specialist if:

• the matter concerns income left out of returns for several years and the tax amount is significant;
• the account belongs to a company, foundation or trust, and a CFC question arises;
• the tax office disputes your non-resident status and the border days are counted differently;
• the demand asks about the source of large sums received in the account;
• the demand came together with a summons to a commission or a notice that an offence report will be drawn up.

At BRIDGES such matters are handled by our tax coordination service: we look at every country where you have accounts, income and residence, and build the reply so that it does not contradict what you file abroad. You can start with an online consultation. If you are only planning a move, it helps to compare countries in advance: the UAE, for example, is often chosen for having no personal income tax, and our note on the CRS standard explains how data exchange works.

Step-by-step action plan

How this article was prepared

The article is based on primary sources: Articles 6.1, 11.2, 29, 31, 81, 88, 93, 93.1, 119, 122, 126 and 129.1 of Part One and Article 207 of Part Two of the Russian Tax Code as currently in force; Article 12 of Federal Law No. 173-FZ on Currency Regulation and Currency Control; Articles 4.5 and 15.25 of the Code of Administrative Offences; and the interview with Federal Tax Service Deputy Head Yulia Shepeleva published on the tax service website on 30 March 2026. The deadline example follows the rules of Articles 6.1 and 31 of the Tax Code. This article does not replace advice on your own situation and contains no recommendations on reducing taxes outside the law.