The customs service transmits data on discrepancies in the Unified State Register of Legal Entities to the Federal Tax Service for 3 days.
The basis is the Order of the Federal Customs Service of Russia dated April 6, 2018 No. 63-R. The document obliges the heads of structural divisions of the Federal Customs Service, regional customs administrations and customs offices to send information to the territorial bodies of the Federal Tax Service about the inconsistency of information about participants in foreign economic activity and persons working in the field of customs affairs with the data contained in the Unified State Register of Legal Entities. The deadline is three business days from the moment the discrepancy is detected.
Discrepancies are checked under sub-paragraphs "c", "d" and "l" of paragraph 1 of Article 5 of Federal Law No. 129-FZ of August 8, 2001 "On State Registration of Legal Entities and Individual Entrepreneurs". We are talking about the address of the legal entity, information about the head and the founders.
After receiving a signal from the customs, the registration authority verifies the accuracy of the information in the register. If the violation is confirmed, a notification is sent to the legal entity, its founders, or a person acting without a power of attorney. It takes 30 days to eliminate the discrepancy: the company must either provide reliable information or provide documents confirming its relevance.
If the company does not respond or the submitted documents do not confirm the authenticity, an entry on unreliability is entered in the Unified State Register of Legal Entities. Six months after such an entry is made, the registration authority has the right to decide on the upcoming exclusion of a legal entity from the register.
The most common reason for checks is the address. The return of mail with notes about the expiration of the storage period or the departure of the organization itself serves as the basis for verification of authenticity. Physical access to the building and the possibility of receiving correspondence at the specified address are mandatory conditions for a foreign economic activity company.
A legal entity is obliged to inform the registration authority about changes in the registry information within seven working days from the date of their occurrence. A change of address, the appointment of a new supervisor, a change in the composition of participants — each of these events requires an application. If the company has specified an email address in the Unified State Register of Legal Entities, letters from the executive authorities must be answered promptly.
For importers and exporters, the practical consequence is obvious: customs sees the actual behavior of the company — delivery addresses, authorized representatives, legal details in the declarations. Any discrepancy with the registry automatically goes to the Federal Tax Service. Regular monitoring of the data in the Unified State Register of Legal Entities and timely updating of information reduce the risk of checks and avoid writing about unreliability.
Related materials:
- LLC or LLC: how one letter in the contract leads to additional charges — what discrepancies in the details do customs consider to be an alarming signal?
- The Federal Customs Service, the Federal Tax Service, and Currency Control: how Big Brother works in Russian Foreign economic activity — what other data do agencies exchange about you?
- Account blocking under 115-FZ: how does a foreign economic activity company get into the blacklist of banks - and is it possible to get out of it — how will a record of unreliability turn into a bank
