Three days ago we wrote about the year-long tax deferral for businesses hit by attacks on the RVB warehouses, and said plainly what we did not know: the decree had not been published, and it was unclear how “damage exceeding 5% of annual income” would be confirmed. The text is now out. The mechanism it sets out is unusual.
The company draws up the list
Under paragraph 4 of decree № 1074, the lists of affected people “are compiled by the company RVB” and sent electronically each month, no later than the 10th, to the Federal Tax Service and the insurer's territorial offices.
Each entry gives the organisation's name or the individual's full name, the taxpayer number, the calculated amount of damage, and the period in which it was incurred. When submitting the next list, RVB may amend information sent earlier. The first list had to be filed within two calendar days of publication.
The tax authorities make no decision
Paragraph 6 leaves no room for interpretation:
“Decisions to grant deferral or payment by instalments for taxes, advance tax payments and social contributions provided for by paragraph 1 of this decree are not issued by the tax authorities or the authorised bodies of the insurer.”
Nor is interest charged — that is paragraph 7. The right to defer therefore arises when someone appears on the list, not from an agency decision.
Damage is calculated under paragraph 3: “using a procedure analogous to that for determining the amount of compensation provided for by clauses 11.3.5 and 11.3.6 of the offer for the sale of goods on the wildberries.ru website dated 7 July 2026”. The offer is on the company's own site.
Who qualifies
There are two conditions, and either is sufficient. The first is that calculated damage from attacks since July 2026 exceeds 5% of taxable income reported in tax declarations. The second is that the person suffered damage and has been registered since 1 December 2025 — here there is no 5% test at all.
The deferral covers VAT (except import VAT), profit tax, the simplified and automated simplified regimes, professional income tax, sole traders' personal income tax and social contributions. On-site audits are also suspended until 31 December 2026 — both decisions to conduct new ones and audits already scheduled.
What this changes in our model
Nothing yet, for the same reason as three days ago: Minfin has given neither the cost of the decision nor the number of taxpayers. The deficit scores 65 out of 100 and remains the strongest of the eight; the rest are on the monitor.
What has changed is not a number but our understanding of the mechanism. The deferral takes effect month by month, starting when a person appears on the list, so its budget impact will emerge gradually rather than all at once.
What we do not know
Most importantly, we do not know what clauses 11.3.5 and 11.3.6 of the offer actually say. The decree only points to them, and it points at a dated version — the offer of 7 July 2026 — while the address it gives serves whatever terms are current. Following the link is no guarantee of reading the text the decree means. Neither the lists nor their size are published, so an outside observer cannot see how many taxpayers or how much money the measure covers.
One more thing: paragraph 9 recommends that RVB itself approve the procedure for compiling the list and agree its submission process with the tax service. The company also writes the rules for building the list.