This item has been updated since its original publication on 20 June 2024 following coming into force of 14th EU package of sanctions.
Readers will be aware that since June 2022 there has been an EU ban on the provision of accounting services to the Russian government and legal entities and persons established in Russia. The banned services include accounting, auditing, including statutory audit, bookkeeping or tax consulting services. Click for more information on the ban on provision of accounting services on the Institute’s website.
Within the regulation imposing the ban there is an exemption for the provision of services intended for the exclusive use of Russian entities which are subsidiaries of EU companies and companies established in certain other allied jurisdictions (The list of jurisdictions has been updated in the 14th package). However, with the 12th package of sanctions, introduced in December 2023 came a wind down of the exemption permitting the provision of restricted business services to those subsidiaries. This wind down had originally been set for 20 June 2024 after which a licence from EU Member States will be required to continue providing services to Russian affiliates. However, the 14th package of sanctions extended this wind down date to 30 September 2024.
The 14th package also introduces an exemption from the ban whereby EU nationals that are residents of Russia (and were so before 24 February 2022) are permitted to provide the prohibited professional services, excluding software, to EU/Western-owned subsidiaries who are their employers.
This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.