Draft Law No. 617-9 amends Article 378.2 of the Tax Code of the Russian Federation, expanding the list of objects for which the tax base is determined based on the cadastral value. The new category includes order acceptance and delivery points, which are qualified as logistics infrastructure facilities of the intermediary digital platform operator.
Prior to the appearance of the draft law, the issue of the tax status of PVZ remained open. The Ministry of Finance and the Ministry of Industry and Trade explained that the assignment of a pick—up point to a commercial facility — and hence the application of a cadastral assessment - should be decided on a case-by-case basis by correlating the actual characteristics of the premises with the characteristics of the commercial facility. This approach created legal uncertainty: some PVZS fell under the cadastral calculation, others did not.
The bill eliminates this uncertainty by introducing a separate basis for cadastral taxation. Now belonging to the logistics infrastructure of the digital platform will become an independent criterion that does not require proof of the commercial nature of the object.
For marketplace operators — Wildberries, Ozon, and other platforms with extensive PVZ networks — the change means a predictable but potentially higher property tax. The cadastral value of commercial real estate in large cities, as a rule, exceeds the residual book value, therefore, the tax burden on objects in dense urban areas will increase.
Sellers who work through third-party PVZS under agency agreements do not have direct tax consequences: the owner of the facility is responsible for paying property tax. However, the rising costs of delivery network operators can translate into tariffs for fulfillment and last-mile delivery services, which ultimately will affect the cost of logistics for sellers.
The amendments are scheduled to enter into force on January 1, 2027. Up to this point, platform operators and PVZ owners should conduct an inventory of facilities, clarify their cadastral value and assess changes in the tax burden by region of presence.
Related materials:
- Ready-made PVZ are being resold: the main asset is the lease agreement — why does the tax on the premises change the price of the finished item
- Sellers' expenses on marketplaces have reached 47.8% of the product price — how much are tariffs already eating up before the new tax
- An individual entrepreneur with several PVZS can apply the administrative tax System — the Federal Tax Service gave the answer — which tax regime is available to the owner of the network of points
