The Russian Federal Tax Service (FTS) recently issued guidance letters No. SD-4-3/7956 and No. SD-4-3/7957, which clarify the required changes for a consolidated group of taxpayers (CGT) following a reorganization. The first letter clarifies that when there is a change in ownership, no change to the CGT is required, provided that one entity maintains at least 90% direct or indirect ownership in the other entities (general CGT condition). If a CGT member entity ceases to meet the 90% ownership…