Foreign experience in identifying shell companies

Shell company is an international phenomenon. Around the world and, in particular, in Europe, the issue of misuse of preferential taxation using front companies and persons is relevant. The European Commission proposes to introduce minimum requirements and criteria for the verification of signs.


Minimum requirements:

  • the company must have owned or rented premises in the EU country;
  • the company must have an active bank account in the EU;
  • the CEO must be a tax resident of the EU or the majority of employees must be tax residents.

Negative signs:

  • more than 75% of revenues come from passive income sources such as interest, dividends, leasing and real estate;
  • more than 60% of assets are located outside the Member State or at least 60% of income is earned or paid out via cross-border transactions;
  • administration and decision-making is outsourced.

Consequences of non-compliance with the requirements:

  • denial of tax benefits, including under double tax treaties;
  • shell company shareholders' income is subject to tax rules similar to Controlled Foreign Corporation, CFC
  • a request for a tax residency certificate for a tax deduction in other jurisdictions will be denied.


  • public companies;
  • companies the activities of which are governed by separate directives;
  • holding companies;
  • companies having passive income and at least 5 internal employees managing the activities;
  • companies operating exclusively within the country.

The proposals of the European Commission to Directive 2011/16/EU on the identification of shell companies will come into effect from January 1, 2024.

The need for information on foreign companies is growing from year to year. The annual increase in requests to the Information and Analytical system Globas for obtaining up-to-date information on foreign companies is 25%.

The capabilities of Globas for checking foreign companies:

  • 400+ million organizations worldwide;
  • online and offline reports;
  • obtaining online reports from the Orbis database by the world's leading publisher of electronic databases for the analysis of companies and markets Bureau van Dijk - Moody's Analytics;
  • wide network of competent partners all over the world;
  • variety of alternative sources;
  • check for the affiliation and links with Russian companies;
  • experts support.
Small food service businesses

According to the changes in the Tax Code of the Russian Federation, adopted by the Federal Law dated 02.07.2021 No 305-FZ, starting from 2022 food service companies are exempt from VAT. The privilege applies mainly to small businesses, whose economic situation in recent years leaves much to be desired, but return on investment continues to grow.

For this ranking the Information Agency Credinform selected the largest companies in terms of annual revenue, according to the data from the Statistical Register and the Federal Tax Service for the latest available accounting periods (2018 – 2020). These companies are registered in the Unified Register of Small and Medium-Sized Businesses of the Federal Tax Service of the Russian Federation and engaged in food service sector (TOP 10 and TOP 100). Then they were ranked by return on investment ratio (ROI ratio) (Table 1). The selection and analysis are based on the data from Globas.

Return on investment ratio is calculated as the ratio of net profit to the amount of equity and long-term liabilities and shows the return on equity involved in commercial activities and long-term attracted funds of the organization.

In order to get the most comprehensive and fair picture of the financial standing of an enterprise, it is necessary to pay attention to all the combination of financial indicators and company’s ratios.

Table 1. Net profit (loss), revenue, ROI ratio, solvency index Globas of the small food service businesses (TOP-10)
Name, INN, region Revenue, million RUB Net profit (loss), million RUB ROI, % Solvency index Globas
2019 2020 2019 2020 2019 2020 2020
1 2 3 4 5 6 7 8
INN 2315152138 Krasnodar Territory
Chain of hotels, restaurants, cafes and shops in Abrau-Durso
up793,8 up878,8 up-57,1 up-4,7 down-2 468,32 up198,22 298 Medium
INN 7808037300 Saint Petersburg
Café chain “Bushe”
up1 594,1 down1 328,2 down120,7 down103,7 down55,71 down34,58 192 High
INN 5047196943 Moscow Region
Chain of fast food restaurants at gas stations
up954,4 up1 040,7 up543,2 down507,8 down47,68 down30,83 262 Medium
INN 5009074422 Moscow Region
Café chain “Kofemaniya”
up1 390,5 down936,5 up226,7 down187,9 up27,85 down18,76 212 Strong
INN 1650100830 Republic of Tatarstan
Catering in educational institutions
up1 571,6 down1 215,6 up86,6 down45,7 up41,93 down18,13 180 High
INN 7727021870 Moscow
Catering in educational institutions, health care, on the territory of the customer
up1 438,0 down1 295,2 up32,0 down16,9 up28,43 down11,50 202 Strong
INN 7729399636 Moscow
Moscow café chain “Kofemaniya”
up1 647,6 down1 598,2 down-112,7 up16,8 down-48,02 down6,66 234 Strong
INN 7728339641 Moscow
International café chain “Cofix”
up1 631,0 down1 310,5 up12,2 down1,0 up23,80 down2,00 277 Medium
INN 7813037232 Saint Petersburg
Organization of hot meals in St. Petersburg for students of educational schools, professional schools, lyceums
up1 576,2 up1 577,3 down3,4 down3,1 down1,82 down1,68 222 Strong
INN 9710013554 Moscow
Burger chain
up1 483,2 down860,9 up77,8 down-4,4 up552,72 down-30,51 345 Adequate
Average value for TOP 10 up1 408,1 down1 204,2 up93,3 down87,4 down-173,64 up29,18  
Average value for the industry up33,1 down29,2 up1,6 up2,2 up32,41 up46,74  

вверх improvement compared to prior period, вниз decline compared to prior period

In 2020 average values of ROI for TOP 10 were below the average values for the industry. Only two companies out of TOP 10 improved their values, meanwhile in 2019 there were five such companies.

Three companies out of ten increased revenue and two increased net profit. At the same time decrease in average revenue value for TOP 10 was 14% and in average industry value it was 12%. Net profit in TOP 10 decreased by 6%, but average value for the industry increased by 38%.

For the past five years, industry average values of ROI ratio were improving for the whole period. The highest value was achieved in 2020 and the lowest was shown in 2016. (Picture 1.).

Picture 1. Change of average industry values of ROI ratio in the food service sector in 2016 – 2020 Picture 1. Change of average industry values of ROI ratio in the food service sector in 2016 – 2020