Russia Introduces Mandatory SPOT System for Imports from EAEU Member States
Key Requirements
As a general rule, importers bringing goods into Russia by road from EAEU Member States must:
- submit a Document on the Intended Supply of Goods (DISG) in electronic form no later than two calendar days before the importation of goods;
- make a security payment in Russian roubles, by bank transfer, in an amount not less than the expected indirect tax liability (VAT and/or excise duties);
- obtain the QR code assigned to the DISG and provide it to the supplier or carrier;
- and retain transaction-related documents for at least five years from the date of importation.
If only part of the goods specified in the DISG is imported, a new DISG must be filed for the remaining goods.Any excess security payment is refundable.
Exemptions from the Security Payment Requirement
The security payment is not required in certain cases, including where:
- the importer is recognised as a major taxpayer;
- the importer participates in the Russian tax monitoring regime;
- goods are sold to individuals through electronic marketplaces;
- or tolling raw materials are imported for processing followed by the export of the processed products.
Additional exemptions may be introduced by the Government of the Russian Federation. Where the security payment exemption applies, the DISG must still be submitted no later than four hours before the importation of goods.
Scope of Application
At present, SPOT applies only to goods imported into Russia from EAEU Member States by road transport.
The Russian Government may subsequently extend the regime to other modes of transport.
The system does not apply to certain categories of goods, including cash, crude oil, electricity and goods imported by individuals for personal use.
Treatment of the Security Payment
The security payment will be credited against the importer’s indirect tax liabilities for the relevant tax period.
Where the amount of the security payment exceeds the assessed tax liability, the excess may be credited towards the taxpayer’s overall tax obligations following:
- completion of the desk tax audit of the relevant tax return;
- or entry into force of the tax authority’s decision based on the results of such audit.
If the importation contemplated by the DISG does not take place, the security payment may still be claimed in the importer’s indirect tax return relating to imports from EAEU Member States. Such claim may be made within three years from the date on which the DISG was filed.
Practical Implications
The introduction of SPOT creates additional compliance obligations for businesses importing goods into Russia from EAEU Member States. Importers should review their logistics and tax compliance procedures to ensure timely preparation of the DISG and, where applicable, advance funding of the security payment.
Companies engaged in regular cross-border trade within the EAEU should assess whether they qualify for any available exemptions and consider the impact of the new requirements on cash flow, supply chain planning and internal compliance processes.
