Tax amendments for 2027: what the bill submitted to the State Duma proposes

Payment deadlines. If a tax or advance payment due date in December falls on a non-business day, the deadline will be moved to the preceding business day. Businesses will need to take this exception into account when planning payments via the Unified Tax Account. Furthermore, the Bill allows deferred tax amounts to be converted into a one-time installment plan once an initial tax deferral period expires, with the total duration of both mechanisms capped at three years. Any denial of an installment request must be reasoned.

Controlled foreign companies. The ownership threshold to qualify as a controlling person under one of the relevant criteria is set to rise from 25% to 50%. Meanwhile, sole control established by a foreign entity’s governing law or constitutional documents will be treated as 100% ownership for the purposes of the Russian Tax Code (“Tax Code”). The Bill also repeals the rule under which profits of a controlled foreign company (CFC) are excluded from the tax base if they do not exceed RUB 10 million. 

Articles 7 and 8 of the Bill extend the special (temporary) rules governing the tax treatment of CFC profits through 2030. Both amendments concern Article 25.15 of the Tax Code and were not included in the initial version of the Bill.

An amendment to Part 4 of Article 7 of Federal Law No. 565-FZ dated 28 December 2022 extends through 2030 the possibility for a Russian entity that is a controlling person to apply the special CFC profit calculation mechanism, provided that the conditions prescribed by the Tax Code are met. At the same time, the eligibility criteria for this special mechanism remain unchanged.

This applies, in particular, where restrictive measures prevent dividends from being paid or profits from being distributed by a foreign entity. When making adjustments to CFC profits, a Russian entity that is a controlling person may, in place of the relevant amount of dividends or distributed profits, use an amount equal to the CFC’s profit calculated in accordance with Article 309.1 of the Tax Code. Compliance with this special treatment must be supported by appropriate documentation.

An amendment to Part 5 of Article 5 of Federal Law No. 595-FZ dated 19 December 2023 also extends until 2030 the transitional rule on the application of the special calculation mechanism to determine CFC profits. The extension covers tax periods from 2026 through 2030.

Transfer pricing and tax monitoring. Taxpayers will be allowed to copy tax audit files onto their own electronic storage devices. Under the proposed rules, certain transfer pricing documents must be accompanied by a notarized Russian translation. To join the tax monitoring regime, meeting any one of the criteria set out in Article 105.26 of the Tax Code will suffice with no further requirement to satisfy all of them simultaneously.

Penalties. The Bill provides for higher penalties for a broad range of tax offenses. In particular, the penalty for violating the tax registration deadline under paragraph 1 of Article 116 of the Tax Code will increase from RUB 10,000 to RUB 30,000; the minimum penalty for failure to file a tax return under Article 119 will increase from RUB 1,000 to RUB 2,600; and the penalty for failure to submit documents under paragraph 1 of Article 126 will increase from RUB 200 to RUB 560 per document.

Intermediary digital platforms to become part of tax administration and control mechanisms.Federal Law No. 289 “On Certain Matters Concerning the Regulation of the Platform Economy” entered into force on 1 October 2026. The Tax Code is therefore proposed to be amended to allow the tax authorities to deliver documents via the information systems of an operator of an intermediary digital platform (the “Platform”) to the personal account of a taxpayer, a payer of fees and social insurance contributions, or a tax agent acting as a partner-seller of the Platform (the “Partner”), including in the course of tax audits. Accordingly, any document sent by the tax authorities through the Platform operator will be deemed to have been received by the Partner three days after the date on which it was sent (Article 31 of the Tax Code).

Furthermore, the Bill introduces a mechanism to suspend order placements and the posting of product, work or service listings on the Platform as an interim measure to secure the fulfillment of tax, fee and insurance contribution payment obligations (Article 72 of the Tax Code).

Specifically, the Bill proposes to introduce Article 77.1 of the Tax Code, enabling the tax authorities to issue a directive suspending or resuming order placements and listings on the Platform. Such directives would be issued to the Platform operator or, simultaneously, to all operators of the platforms where the Partner’s product, work or service information is listed. The Platform operator will be required to execute the directive within two days of its receipt. At the same time, the Platform operator will be responsible for notifying the tax authorities of any suspension or resumption of order placements and listings on the Platform.

If the Partner fails to submit the documents or information requested by the tax authorities, the above interim measure may be imposed no earlier than three days and no later than one month after the deadline for submitting the requested documents has expired.

If the Partner submits the requested documents or information, the tax authority will instruct the Platform operator to resume order placements and the posting of listings no later than two days thereafter.

The Tax Code is also proposed to be supplemented by Article 86.6, requiring the Platform operator to identify, based on a list of criteria established by the Federal Tax Service, risks of incorrect calculation, underpayment and/or late payment of taxes, fees and social insurance contributions by the Partners, and notify the Partners of such risks through their personal accounts. The Partner will have 30 calendar days to provide the Platform operator with documents or information refuting the identified risks. The operator will then be required to forward these documents or information to the tax authority through information systems meeting requirements established for information exchange with the tax authority, including those concerning the data composition, storage and processing. 

The Bill provides for a RUB 100,000 penalty for an operator’s failure to execute a directive from a tax authority to suspend or resume order placements and listings, as well as for failure to perform its tax control obligations (Article 129.17 of the Tax Code). At the same time, based on the current wording of the Bill, it remains unclear whether the penalty will apply separately to each instance of the operator’s failure to comply with a directive and/or perform its tax control obligations.

It should be noted that, if enacted, these provisions will take effect nine months following the date of official publication of the law.

Accordingly, platforms will be vested with certain tax administration functions aimed at facilitating interaction between tax authorities and Partners. Given the tight deadlines, the proposed changes will increase the administrative burden on Platform operators and make interactions between Platforms and Partners more complex. Partners should be prepared to respond promptly to tax authority requests through the Platform; otherwise, their activities on the Platform may be suspended, which could adversely affect not only their revenue but, ultimately, tax revenues to the budget.

Expenses related to protection against unmanned aerial vehicles.  The Bill introduces CIT deductions for the cost of meals provided to people staying in shelters and similar protective facilities, as well as the value of property, work, services and property rights transferred free of charge to the government agencies and units specified in the Bill for the protection of people and property against unmanned aerial vehicles (UAVs). Deductible expenses will also include the costs of equipment, food supplies, and the provision and maintenance of facilities used to accommodate and deploy the relevant units (subparagraph 48.16 of paragraph 1 of Article 264 and subparagraphs 19.17 and 19.18 of paragraph 1 of Article 265 of the Tax Code).

Time chartering of ice-class vessels. Under subparagraph 33.4 of paragraph 1 of Article 251 of the Tax Code, shipowners are exempt from CIT on income derived from the operation of ice-class vessels entered in the Russian International Register of Vessels. The Bill expressly includes payments received under a time charter agreement among such income. This clarification is relevant to shipowners that make eligible vessels available for temporary use under this contractual arrangement; all other exemption criteria remain unchanged.

Amendments regarding the regional investment tax credit. Companies operating under primary activity (OKVED) codes 05–09 will not be able to benefit from the regional investment tax credit to reduce the federal component of their CIT pursuant to paragraph 3 of Article 286.1 of the Tax Code. The restriction covers the extraction of coal, oil, natural gas, metal ores and other minerals, as well as related mining services. A company’s primary OKVED code will be verified against the Unified State Register of Legal Entities (EGRUL) as of 1 January of the tax period in which the tax credit was first claimed.

The Bill proposes to set up a 35% tax rate for dividends credited to Type C accounts designated under Decree No. 95 of the President of the Russian Federation dated 5 March 2022. For individuals, such payments will be included in the list of income subject to PIT at the 35% rate in accordance with paragraph 2 of Article 224 of the Tax Code. The list currently includes, in particular, certain types of material gain, promotional prizes to the extent they exceed the tax-free threshold, and income received by members of credit consumer cooperatives.

For foreign entities, the Bill introduces a 35% withholding tax rate instead of the generally applicable 15% rate (new subparagraph 3.1 of paragraph 3 of Article 284 and paragraph 1 of Article 310 of the Tax Code). On a literal reading, the special rate applies where both conditions are met: (i) the income is in the form of dividends and (ii) is credited to a Type C account. Consequently, payments that are not credited to such accounts should not fall within the new rule merely because they have an economic nature similar to dividends. At the same time, in practice, questions may arise as to whether the rule applies to income treated as dividends for tax purposes, including as a result of secondary adjustment or recharacterization of interest income. Dividends paid in kind, where no funds are transferred to an account, will require separate consideration.

The Bill also does not address the issue of refunds of tax withheld in excess where grounds for applying a different tax treatment are established after the payment has been made. For instance, this may occur where information on a controlled foreign company and the person having the actual right to dividends is subsequently disclosed to the tax agent. The procedure for applying the new rule in such circumstances requires further clarification.

The Bill introduces significant changes to the tax regime applicable to closed-end and interval mutual investment funds intended for qualified investors, as well as to the taxation of their unitholders. From 1 January 2027:

— Closed-end and interval mutual investment funds intended for qualified investors will be recognized as CIT taxpayers (paragraph 1 of Article 246 of the Tax Code).

Under the current version of the Bill:

• The composition of the assets of mutual investment funds intended for qualified investors, the number and composition of their unitholders, and the purpose for which a Fund is established (including, for example, sanctions-related considerations) will not affect its status as a CIT taxpayer.
• The tax regime for open-end mutual investment funds will not change.

Accordingly, the tax regime for mutual investment funds not intended for qualified investors should remain unchanged. 

— Taxable income will comprise income specified in subparagraphs 1–4 and 8 of paragraph 4 of Article 309.1 of the Tax Code and derived from the fiduciary management of property comprising the Fund.

Accordingly, closed-end and interval mutual investment funds intended for qualified investors will be subject to tax on the following types of income:

• Dividends
• Income derived from the distribution of profits or property of entities, other persons or their associations, including upon their liquidation
• Interest income from any debt obligations, including profit-sharing and convertible bonds
• Income from the use of intellectual property rights
• Income from the lease or sublease of property, including income from leasing transactions, except for income from the lease or sublease of seagoing vessels, combined river-sea navigation vessels, aircraft and/or vehicles, as well as containers used in international transportation, and income from the lease or sublease of  underground gas storage facilities and pipelines used in hydrocarbon transportation 

Under the current version of the Bill, the following types of income fall outside the proposed scope of taxation:

• Income from the disposal of shares (equity interests) in a foreign entity and/or the assignment of rights in a foreign entity that is not a legal entity under the laws of its jurisdiction
• Income from transactions involving derivative financial instruments
• Income from the disposal of immovable property
• Income from the disposal (including redemption) of investment units in mutual investment funds

It should be noted that the list of income of mutual investment funds set out in paragraph 1 of Article 246 of the Tax Code does not expressly refer to income from transactions involving derivative financial instruments. However, paragraph 5 of Article 247 of the Tax Code contains a reference to such income.

— Taxable income is determined in accordance with subparagraphs 1–4, 6 and 8 of paragraph 4 of Article 309.1 of the Tax Code (paragraph 5 of Article 247 of the Tax Code).

As noted above, paragraph 5 of Article 247 of the Tax Code also refers to income from the disposal of derivative financial instruments as income of the relevant mutual investment funds, whereas paragraph 1 of Article 246 of the Tax Code does not. 

A key issue is whether income is to be determined on a gross or net basis. As currently drafted, the Bill may be construed as subjecting all types of income to CIT on a gross basis, with no deduction of any related expenses. This could result in a higher tax burden in certain cases. 

— The tax agent rules applicable to depositories, issuers, brokers and other entities that act as tax agents when paying dividend and interest income will remain unchanged for payments made to the relevant mutual investment funds. In other words, depositories, issuers and brokers will not be required to withhold CIT when making payments to the relevant mutual investment funds (paragraphs 3 and 4 of Article 275 of the Tax Code). 

— The management company will act as the tax agent in respect of income earned by the relevant mutual investment funds (Article 276.1 of the Tax Code). As a tax agent, the management company will be required to calculate the tax and remit it to the budget no later than the 28th day of the month following the month in which the relevant income is received, unless otherwise provided by the Tax Code (Article 287 of the Tax Code). 

— The management company will be required to calculate the amount of CIT withheld from the Fund’s income during the current tax period that is attributable to each unitholder, and notify the unitholders or depositories accordingly, as well as notify them of the DDU indicator and the total amount of income from fiduciary management paid to all recipients during the tax period (Article 276.1 of the Tax Code). 

The calculation is to be made in proportion to the amounts payable to unitholders from the Fund, using the following formula:

ZNP_DU = BZ_DU х 0.15, where:

• ZNP_DU is the amount of CIT eligible for offset
• BZ_DU is the tax base used to determine the amount of CIT eligible for offset, equal to the lower of:
  • the amount of income specified in paragraph 5 of Article 247 of the Tax Code derived from fiduciary management and paid during the tax period, in respect of which CIT was calculated for the taxpayer; and
  • the product of the KDU and DDU indicators, where:
    • KDU is the ratio of the amount of income from fiduciary management paid to the taxpayer during the tax period to the total amount of income from fiduciary management paid to all recipients during the tax period
    • DDU is the total amount of income specified in paragraph 5 of Article 247 of the Tax Code received by the Fund during the tax period, in respect of which CIT was calculated and remitted to the budget in accordance with paragraph 7 of Article 287 of the Tax Code and which was not previously included in the DDU calculation. 

Accordingly, management companies will need to implement the relevant procedures and processes and, where necessary, develop and approve the methodological approaches required to perform these calculations and notify unitholders (depositories).

— It is currently unclear whether mutual investment funds will be subject to CIT on a cash basis or on an accrual basis. 

— When receiving distributions from the relevant Funds, unitholders will be entitled to offset the amount of CIT calculated and withheld by the management company that is attributable to the relevant unitholder against the tax payable on such income.

At this stage, it remains unclear whether such an offset will be available in certain circumstances.

Overall, the offset mechanism should, in principle, neutralize the effect of the increased tax burden, with the main effect being a partial unwinding of the tax deferral on income of mutual investment funds. Accordingly, the tax burden may remain unchanged for certain Funds. However, in practice, the tax burden could be higher in some cases.

— A flat tax rate of 15% will apply to all income earned by mutual investment funds. Accordingly, no special reduced tax rates will be available. CIT will be payable to the federal budget (paragraph 1.21 of Article 284 of the Tax Code). 

Given the above, it is worth noting that in planning a restructuring of asset-holding by management companies and taxpayers, it is important to be able to demonstrate a valid business purpose for the restructuring. Furthermore, since the respective mutual funds will be recognized as CIT taxpayers, transactions with them may fall under transfer pricing regulations. 

The current version of the Bill leaves a number of practical application issues unresolved and may give rise to certain tax inefficiencies in specific circumstances. These issues could affect the assessment of the tax efficiency of the respective investment structures from 2027 onwards. Please contact us if you would like to receive further information or a summary of key issues to consider.

The tax rate applicable to income earned by a personal foundation is proposed to be increased to a standard flat rate of 22%, compared with the current flat rate of 15%. As a result, the tax treatment of personal foundations may become less favorable than, or broadly aligned with, the PIT treatment of income received by an individual who is a beneficiary of the personal foundation and a Russian tax resident. Accordingly, using a personal foundation solely for tax planning purposes, rather than, for example, for succession planning or asset protection purposes, may no longer be economically viable.

Income from related parties. The Bill does not contain the previously announced amendments under which income received from related parties would be excluded from the 70% qualifying IT income threshold for the purposes of the CIT incentive and reduced social insurance contribution rates (paragraph 1.15 of Article 284 and paragraph 5 of Article 427 of the Tax Code). Accordingly, the previously discussed restriction is no longer included in the draft legislation. At the same time, the explanatory note continues to refer to measures aimed at preventing the artificial inflation of the share of qualifying IT income through transactions with related parties. This issue should therefore continue to be monitored. 

Expansion of qualifying activities. The list of qualifying income is proposed to be expanded to include income from providing access to electronic books, other electronic publications and graphic images. 

Additional restrictions. At the same time, failure to submit annual financial statements to the tax authorities within six months after the end of the preceding period will become a standalone impediment to applying IT tax incentives.

A new category of VAT taxpayers is being introduced: individuals purchasing e-commerce goods imported into the EAEU territory where the value of such goods is below the applicable customs duty-free threshold.

The Bill introduces new Articles 174.4 and 174.5, which establish specific rules for the calculation and payment of VAT on e-commerce goods purchased by individuals and imported into the Russian Federation. The rules distinguish between goods whose value does not exceed the applicable duty-free import threshold and whose value exceeds it. 

Under the Bill, the obligation to pay VAT will be imposed on tax agents, comprising three categories of persons (1) foreign sellers supplying goods through their own online platforms, (2) foreign online marketplaces acting as intermediaries for other foreign sellers, and (3) Russian marketplaces through which goods supplied by foreign sellers are sold. 

The Bill also clarifies the time at which the tax base is determined, the rules for determining the tax base where the value of goods is denominated in a foreign currency, the tax treatment of returned or refused goods, the VAT payment period and other related matters. 

These changes bring the VAT treatment of cross-border e-commerce closer to the rules already applicable to sellers from EAEU countries. As a reminder, amendments that took effect on 1 July 2024 require companies from EAEU countries to pay VAT on goods sold to Russian consumers through online marketplaces. The proposed rules would now extend similar requirements to all foreign sellers of goods through online channels. 

The proposed changes are expected to result primarily in an additional administrative burden for Russian marketplaces. They will need to configure their accounting and tax systems to comply with the new Russian tax requirements, review the relevant provisions of existing contracts with counterparties and customers, assess a number of methodological issues arising from the new VAT payment mechanism for goods sold through electronic trading platforms, and make corresponding adjustments to the format of invoices and other  primary accounting documents.

In addition, foreign suppliers resident in non-EAEU countries, as well as foreign intermediaries acting as tax agents, will be required to register with the Russian tax authorities, file VAT returns and pay VAT to the Russian budget.

The Bill proposes a number of clarifications to the VAT rules, including the following:

Subparagraph 19 of paragraph 2 of Article 146 of the Tax Code is being amended to provide that the gratuitous transfer of property to the state treasury is not subject to VAT (previously, this provision applied only to transfers of real estate).

New subparagraphs 31 and 32 of paragraph 2 of Article 146 provide that the following transactions will not be subject to VAT: (i) the gratuitous transfer of goods (performance of work, provision of services) to the Ministry of Defense and organizations under its authority for the purposes of protecting individuals and/or property against UAVs, and (ii) the gratuitous provision of food to individuals staying in protective structures, basements and other similar facilities owned or otherwise legally held by the taxpayer, for the purposes of protecting such individuals against UAVs. 

The VAT exemption under subparagraph 20 of paragraph 2 of Article 149 for services provided by organizations operating in the culture and arts sector will also be extended to individual entrepreneurs. Such services include, for example, the sale of admission tickets and season tickets for theatrical, cultural and educational, and entertainment events.

The key change with the broadest impact on businesses is the proposed increase in excise duty rates for 2027–2029, which will affect most categories of excisable goods. 

The amendments also introduce a number of targeted changes to Chapter 22 of the Tax Code. In particular:

• The per-tonne calculation of the excise duty rate applicable to petroleum feedstock has been clarified (paragraph 8 of Article 181 of the Tax Code)
• Article 181 of the Tax Code, which sets out a list of excisable goods, has been amended. In particular, grape must will be treated as an excisable product, provided that its ethyl content exceeds 0.5% by volume. Revised criteria are also introduced for vacuum gas oil and fuel oil to qualify as petroleum feedstock: they must be mixtures of hydrocarbons meeting specified physical and chemical parameters.
• The amendments affect Article 200 of the Tax Code, which establishes taxpayers’ rights to claim excise duty credits in respect of certain excisable goods. For a number of such goods, the calculation of the credit amount involves the use of coefficients and indexed notional values of the average wholesale prices of jet fuel and class 5 motor gasoline.
• Excise duty credits claimed by manufacturers of alcoholic and/or alcohol-containing products will be subject to reporting together with the submission of a prescribed set of supporting documents to the tax authorities (paragraph 1 of Article 201 of the Tax Code).
• A separate clarification has been introduced to Article 179.7 of the Tax Code. The requirement relating to the volume of certain petroleum products produced from petroleum feedstock is proposed to apply separately to each oil refinery.

As part of the 2027–2029 budget package, the Russian Ministry of Finance has proposed introducing a windfall tax on all subsoil users.  The current version of the Bill provides for the following structure of the tax:

• Taxpayers are all subsoil users in the Russian Federation.
• The taxable item is the windfall income of subsoil users, determined as follows:
  • 2026:  the increase in the average 2026 price, in rubles, per tonne of extracted mineral resource of at least 10% compared with the average 2025 rice per tonne of the relevant mineral resource in the global market
  • 2027:  the increase in the average 2027 price, in rubles, per tonne of extracted mineral resource of at least 10% compared with the average 2025 rice per tonne of the relevant mineral resource in the global market, multiplied by a coefficient of 1.1
  • 2028:  the increase in the average 2028 price, in rubles, per tonne of extracted mineral resource of at least 10% compared with the average 2025 rice per tonne of the relevant mineral resource in the global market, multiplied by a coefficient of 1.21
• The average global market price is calculated as the product of the arithmetic average price of the relevant mineral resource in US dollars for all trading days and the arithmetic average USD/RUB exchange rate.
• The increase in the value is calculated in respect of ferrous and non-ferrous metals, non-metallic mining and chemical raw materials, mining and chemical raw materials containing metals, and semi-products containing precious metals.
• The tax base is the monetary value of windfall income, calculated as the volume of the relevant mineral resource extracted during the respective year, multiplied by the excess of the average global market price for the respective year over the corresponding 2025 price (for 2028 and 2029, the relevant price should also be multiplied by 1.1 and 1.21, respectively).
• The tax rate is generally 30%; for the tax base attributable to gold, the rate is 20%.
• The tax payable may not exceed the difference between the estimated revenue from the sale of the extracted mineral resource multiplied by 0.15 and the amount of mineral extraction tax (MET) assessed for the entire relevant year. Estimated revenue is calculated as the volume of the extracted mineral resource multiplied by the average global market price.
• The tax is expected to apply for three years (2027–2029) and is to be paid no later than 28 April of the year following the relevant reporting year.
• The Bill also provides for deferral of payment where the amount of windfall tax assessed exceeds 4% of the estimated revenue from the sale of the mineral resource. In such cases, an amount equal to 4% of the estimated revenue is payable during the relevant reporting period, while the excess amount is payable no later than 28 April 2029.
• If adopted, the law will enter into force on 1 January 2027.

The proposed tax could significantly increase the tax burden on companies in the mining and metals sectors. At the same time, the Bill may be subject to further amendments that could potentially change the tax mechanism. Companies should therefore closely monitor the Bill as it progresses through the legislative process.

The Bill restricts the extension of eligibility for MET incentives for companies transitioning between statuses as participants in regional investment projects, residents of advanced development zones, or residents of special economic zones, including by way of succession. 

In particular, residents of advanced development zones that were previously participants in, or successors of participants in, regional investment projects or any special economic zones will not be able to apply a reduced coefficient reflecting the territory where minerals are extracted (Kte). 

Furthermore, participants in “non-listed” regional investment projects (for which inclusion in the register of participants in regional investment projects is not required) that were previously participants in, or successors of participants in, advanced development zones or any special economic zones forfeit their eligibility for the preferential Kte coefficient. These changes warrant attention from companies participating in regional investment projects, as the current version of the Bill does not provide for any transitional provisions with respect to existing tax relations.

Certain targeted amendments address gas extraction in Kamchatka under infrastructure investment agreements, calculation of gas sales for households and a special oil tax credit for eligible companies operating in the Nizhnevartovsk region.

Significant changes have been introduced to the property tax treatment of order pickup points integrated in the logistics infrastructure of platform operators. The tax base for such property will now be determined based on its cadastral value (Article 378.2 of the Tax Code).

The Bill revises the amounts of certain state duties, as well as the list of legally significant actions subject to a state duty. The following revisions have the greatest relevance for businesses:

Fire safety duties: RUB 300,000 for issuing a license for the installation, maintenance and repair of fire safety equipment or the conduct of firefighting activities; RUB 100,000 for adding addresses, types of work or services to the register; RUB 5,000 for other changes. The fee for the certification of a fire protection design specialist will be RUB 100,000.

Protection of confidential information: state duties for the issuance, reissuance or renewal of licenses for the development and manufacture of information protection products and for the technical protection of information will range from RUB 5,000 to RUB 50,000, depending on the relevant procedure.

Companies and individuals that may be affected by the proposed amendments should consider assessing their potential impact on existing asset-holding structures and the future tax burden.

As the Bill is currently being reviewed by the State Duma, its provisions may be revised. We will continue to monitor its progress and will keep you updated on any significant changes ahead of the second reading. B1 is ready to assist you in assessing the implications of the proposed rules for specific transactions and draft an implementation plan. Our professionals can also provide comments and clarifications on any ambiguities or matters not addressed by the proposed amendments that may need to be taken into account when assessing the potential effect of the new legislative initiatives.