Russia · Tax regime
Russian tax residence and the CFC fixed-profit regime
Current for the 2026 tax year. The five-band personal scale has run since 1 January 2025; VAT rose from 20% to 22% on 1 January 2026 with no transition relief; the CFC fixed-profit election has been priced per company rather than at a flat rate since the 2025 tax period.
The genuine attraction is what is absent. Russia has no wealth tax, no inheritance or estate tax — both abolished in 2006, leaving only a notarial duty capped at RUB 100,000 for close heirs — and no exit tax on individuals. For a family whose planning problem is succession rather than income, that combination is rarer than it sounds. The offsetting cost is that controlled foreign company rules are real and expensive, and that treaty relief has been switched off with most of the West.
Qualifying routes
Settled per calendar year. There is no domicile test, no centre-of-vital-interests test in domestic law and no split-year treatment — you are resident or non-resident for the whole year.
RUB 5m a year of tax for one controlled foreign company, rising to about RUB 25m for five or more, and it locks you in for at least five consecutive tax periods.
The facts
- Total landed cost
- Personal income tax of 13% to 22% on a five-band scale, with dividends, deposit interest and property sales each running their own separate 13%/15% base. No wealth tax, no inheritance tax, no exit tax.
- Route type
- Tax regime, not a visa
- Physical presence
- 183 calendar days in any twelve consecutive months. Short absences of up to six months for medical treatment or education do not break the count.
- Permanent residency
- None. Tax residence and immigration status are separate systems in Russia and neither produces the other.
- Citizenship
- None
- Language test
- Not applicable
- Dual citizenship
- Permitted
- Requirements
- 183 calendar days of physical presence in any twelve consecutive monthsan annual controlled foreign company notification by 30 April, whether or not the fixed-profit election is madefor Russian citizens, notification of foreign accounts within one month and an annual movement-of-funds report by 1 June
- TREATY RELIEF IS LARGELY GONE. Presidential Decree No. 585 of 8 August 2023 suspended the operative articles of 38 double tax treaties with states Russia designates unfriendly, including dividends, interest, royalties, capital gains and employment income. The exchange-of-information articles were left in force, so you keep the compliance burden and lose the benefit. The United States treaty is suspended in both directions, with US withholding at the statutory 30% since 16 August 2024.
- Withholding tax on interest and royalties leaving Russia is 25%, not 20% — raised on 1 January 2025. A great deal of published commentary still repeats the old figure.
- The CFC fixed-profit election is expensive and sticky: RUB 5m a year for a single company, up to roughly RUB 25m for five or more, and a five-year lock-in. Nothing about the 2025 repricing helps a single-company holder.
- The RUB 2.4m threshold applies per tax base, not to total income, and the bases do not aggregate. Salary, dividends, deposit interest and property sales each run their own.
- A non-resident selling Russian property inside the minimum holding period pays 30% on the entire sale price, with no deduction for what they paid for it. Meeting the period — five years, or three in listed cases — takes it to zero.
- Russian citizenship carries currency-residence duties for life, independent of tax residence: notification of every foreign account within a month and an annual report on the movement of funds by 1 June. The relief for spending more than 183 days abroad is re-tested every year, so one year mostly spent in Russia switches the duties back on.
- Financial account data no longer flows from the EU, the UK, the US or Switzerland to the Russian tax authority — 26 EU member states came off Russia's exchange list at the end of 2024. That is not privacy: it triggers Russian restrictions on what a resident may credit to an account in a non-exchanging country, and mandatory audited accounts for controlled foreign companies there.
- Russia was added to the EU's own anti-money-laundering high-risk list by Delegated Regulation (EU) 2026/46, applicable from 29 January 2026, and has sat on the EU tax blacklist since February 2023. Enhanced due diligence on any Russia-linked relationship is now legally mandatory across the EU, and de-risking is the common outcome. Expect account refusals and source-of-wealth demands elsewhere for as long as you hold Russian residence.