Concept
After 2022, relocation from Russia became widespread. Choosing a destination involves opening a bank account, obtaining a residence permit and determining the tax consequences. Four destinations are considered most often — Armenia, Kazakhstan, Georgia and the UAE. Each has its own advantages and risks.
Key conditions for the four destinations.
| Who it affects | Individuals with Russian tax residency moving to Armenia, Kazakhstan, Georgia or the UAE |
|---|---|
| Residency rule | Article 207(2) of the Russian Tax Code; status for the period fixed by the calendar year (Article 216) |
| Threshold for loss of tax residence | Fewer than 183 days of presence in Russia over 12 consecutive months |
| Russian PIT | 13–22% on the main tax base of a tax resident; a non-resident pays 30% on Russian-source income as a rule and 15% on dividends from Russian companies, while pay for remote work for a Russian employer stays on the 13–22% scale (Article 224(3) and (3.1); Federal Law No. 389-FZ) |
| Local income tax | Armenia 20%; Kazakhstan 10% and 15% above the threshold; Georgia territorial; UAE 0% |
| Treaty with Russia | Armenia and Kazakhstan in force; Georgia none; UAE ratified by Federal Law No. 189-FZ of 7 July 2025, applied from 1 January 2026 |
| Banking | Easiest in Armenia and Kazakhstan (EAEU framework); Georgia and the UAE screen the Russian connection harder |
| Currency control | Notifications and reports lifted after more than 183 days outside Russia in a calendar year (Part 8 of Article 12 of Law No. 173-FZ) |
Russian tax context
Russian tax residency is lost once a person has spent fewer than 183 days in Russia during a calendar year; a non-resident pays Russian personal income tax only on Russian-source income. From 2025 the main PIT scale became progressive — five bands from 13% to 22% depending on the level of income. A separate exception applies to remote workers: under Federal Law No. 389-FZ, pay of remote employees of Russian companies (from 2024) and, from 2025, fees for work, services or licences delivered online through Russian domains, servers or information systems where the payer is Russian, the money goes to a Russian bank account or the recipient is a Russian tax resident count as Russian-source income (Article 208(1)(6.2) and (6.3)) and are taxed on the same 13–22% scale regardless of residency, with the elevated 30% non-resident rate not applying to them (Article 224(3) and (3.1)). In parallel, Decree No. 585 of 8 August 2023 suspended the key provisions of double-tax treaties with 38 'unfriendly' countries; the foreign-tax-credit mechanism and the exchange of information are formally preserved.
Russian domestic law has no centre-of-vital-interests test for individuals; that criterion operates only in treaty tie-breakers, once the new country also treats the person as its own resident and residence in two countries arises.
Armenia
Armenia is an EAEU member: entry on an internal passport, straightforward account opening and residence permits, and accommodating banks. Personal income tax is a flat 20% for residents and non-residents alike; for micro-business with turnover up to AMD 24 million (about USD 60,000) the rate is zero, but from 1 July 2025 legal, accounting and consulting services and software development are excluded from both the micro regime and the turnover tax. Turnover tax rates were raised from 1 January 2025 and now differ by activity.
| Activity | Turnover tax rate |
|---|---|
| Trade | 10% |
| Manufacturing | 7% |
| Catering | 12% |
| High-tech | 1% |
A person becomes a tax resident after 183 days of presence over any 12-month period, or by moving their centre of vital interests to the country. The double-tax treaty with Russia remains fully in force, which simplifies the elimination of double taxation.
Kazakhstan
Kazakhstan is also part of the EAEU, so the procedures for obtaining an IIN, bank cards and a residence permit are well established. From 1 January 2026 a new Tax Code came into force: instead of the former flat 10%, it introduces a progressive scale — 10% on annual income up to about 8,500 MCI (on the order of USD 65,000–70,000) and 15% on the amount above that threshold. The double-tax treaty with Russia is in effect, though banks have noticeably tightened compliance checks and request proof of the source of funds.
Georgia
Georgia has a territorial system: foreign-source income of individuals is, as a rule, not taxed. The local regimes include Small Business Status and the High Net Worth Individual programme.
| Small Business Status | 1% on turnover up to GEL 500,000 (about USD 180,000) for individual entrepreneurs; 3% above the limit |
|---|---|
| Loss of status | Threshold exceeded two years in a row |
| HNWI: assets | Confirmed assets above GEL 3 million |
| HNWI: income | Above GEL 200,000 in each of the last three years |
| Additional condition | A Georgian residence permit or citizenship, or at least GEL 25,000 of Georgian-source income for the year |
| Visa-free stay | Up to 365 days for citizens of many countries |
Tax residency can therefore be obtained without 183 days, but the wealth test alone is not sufficient. Disadvantages include the absence of a double-tax treaty with Russia (there have been no diplomatic relations since 2008) and a more cautious attitude of banks toward new clients from Russia.
UAE
The UAE offers zero personal income tax for individuals and a residence permit through a free-zone company or a property purchase. The key change is the new comprehensive double-tax treaty: it was signed on 17 February 2025, entered into force on 18 July 2025, and applies from 1 January 2026; withholding tax on dividends, interest, and royalties is capped at 10% where a UAE tax residency certificate is held. The treaty replaced the narrow 2011 agreement, which covered only state investment funds, and became available to private business and individuals, including free-zone residents. From 1 January 2026 Russia removed the UAE from the Finance Ministry's lists of offshore zones. Corporate tax in the country is 9% on profit above AED 375,000; there is still no personal income tax.
Day-count Rules for Tax Residence
In all four countries the basic test is the same — 183 days of presence over 12 months, after which a person becomes a local tax resident and pays tax on worldwide income. Georgia offers an alternative through High Net Worth Individual status, and the UAE has Cabinet Decision No. 85 of 2022: the 90-day threshold in Article 4 is open only to UAE and GCC nationals and to holders of a valid UAE residence permit, and additionally requires a permanent place of residence or employment or business in the country. Until the days are accumulated in any one jurisdiction, it is easy to remain a resident of two states at once; such a conflict is resolved by the tie-break rules of the relevant treaty — by permanent home, centre of vital interests, and citizenship.
Treaties and tax credit
Russia has full double-tax treaties with Armenia and Kazakhstan, so tax paid there is usually credited against the Russian tax and vice versa. With the UAE this mechanism only started working from 2026, and with Georgia there is no treaty at all — double taxation is relieved only by the unilateral rules of the national codes. Decree No. 585 additionally suspended some articles of the treaties with 'unfriendly' countries, but it did not affect the foreign-tax credit or the basic residency rules. In practice, dividends, interest, and royalties flowing from Russia to a resident of an 'unfriendly' jurisdiction are now often taxed at source at the full domestic rate.
Automatic exchange and transparency
Armenia, Kazakhstan, Georgia, and the UAE all take part in CRS, so information about the accounts of their tax residents is automatically sent to the owners' countries of tax residence. Russia has effectively dropped out of automatic exchange with most 'unfriendly' countries. Of the four destinations, the FNS list (order of 14 October 2025 No. ED-7-17/883@) names Armenia, Kazakhstan and the UAE; Georgia is not on it, so no automatic exchange of financial information runs between Georgia and Russia.
Currency control
Every Russian citizen remains a currency resident and as a general rule must notify the Federal Tax Service of opening foreign accounts and file cash-flow reports. Part 8 of Article 12 of Law No. 173-FZ lifts both duties for those who have spent more than 183 days outside Russia in a calendar year — the same threshold that ends tax residency.
Banking Requirements and Practice
In practice, banks in all four destinations ask for proof of the source of funds, a local tax number, and often a residential address. Armenia and Kazakhstan are the easiest places to open an account — the common EAEU framework helps; for retail needs in Kazakhstan local fintech options are also convenient. Georgian and Emirati banks scrutinise new clients from Russia more closely and may request additional documents on the origin of capital. Among European destinations, Serbia offers comparably accessible banking: a non-resident on a Russian passport opens an account there on a personal visit, and the outcome depends on the bank's ownership group (see Serbian banks).
Ten Destinations by Eight Relocation Criteria
Armenia, Kazakhstan, Georgia and the UAE are four of the ten destinations most often compared for relocation from Russia. Their conditions differ in entry, taxation, treaty application, automatic exchange and banking. A residence permit does not itself change the treaty, exchange or banking position.
| Destination | Status and route | Local tax on foreign income, and the regime | Time to permanent residence or a passport |
|---|---|---|---|
| UAE | Residence visa through a free-zone company or a property purchase | No personal income tax; corporate tax 9% above AED 375,000. Residence at 183 days, or 90 days for a permit holder with a home or a business there (Cabinet Decision No. 85 of 2022, art. 4) | Practically none — the route gives neither permanent residence nor a passport |
| Kazakhstan | EAEU: well-established procedures for obtaining an IIN, bank cards and a residence permit | New Tax Code from 1 January 2026: 10% up to roughly 8,500 MCI and 15% above it, on worldwide income of a resident | — |
| Armenia | EAEU: entry on an internal passport, straightforward permits | Flat 20% for residents and non-residents alike; turnover tax 1–12% by activity; residence at 183 days or by centre of vital interests | — |
| Georgia | Short-term, investment (real estate from USD 150,000 since 1 March 2026) and work permits, plus the separate right to labour activity | Territorial: foreign income of an individual is generally untaxed; 20% on Georgian income, 1% for small business up to GEL 500,000; residence at 183 days or through HNWI status | — |
| Turkey | Short-term ikamet on own property from USD 200,000; the digital-nomad permit from USD 3,000 a month; citizenship by investment from USD 400,000 | Worldwide income of a resident (art. 4 GVK: a permanent home and centre of life, or more than six months); the 20/D regime needs three years without a Turkish tax connection | Long-term permit after 8 years of continuous residence; a passport in 6–12 months on the investment route |
| Serbia | A single permit for up to 36 months; real estate is accepted as a ground with no minimum value | Worldwide income of a resident; residence under art. 7 of the personal income tax law — a permanent home, a centre of business and vital interests, or 183+ days | Permanent residence after 3 years, citizenship 3 years later — six years and more in practice |
| Cyprus | Employment and business routes; fast-track permanent residence on real estate from €300,000 | Non-dom: 0% on dividends and interest for 17 years, with an effective GeSY charge of 2.65% up to an income ceiling of €180,000; residence at 183 days or on the 60-day rule with real ties | Permanent residence by investment at once; citizenship after 7 years within the last 10 |
| Spain | Residence permits under the general rules; the Beckham regime is elected separately | Beckham (art. 93 LIRPF): for the year of the move and the next five, tax as a non-resident — 24% on employment income (all of it treated as Spanish) up to €600,000 and 47% above, 19–30% on Spanish-source savings income, foreign passive income not taxed; wealth tax IP (by real obligation, art. 93(1)) and the ITSGF backstop reach only assets in Spain | Citizenship after 10 years of legal residence |
| Portugal | The D8 visa for remote workers; the golden visa from €500,000 into CMVM-regulated funds | IFICI: 20% on qualifying Portuguese professional income and exemption with progression for foreign income — but not for pensions, and not for income from blacklisted jurisdictions, which is taxed at 35% | Citizenship 7 years for citizens of the EU and the CPLP, 10 for everyone else, counted from the residence card |
| Israel | Aliyah for those eligible — citizenship is obtained with the status rather than later | Ten years with no tax on foreign income and gains; for residents from 1 January 2026 the reporting exemption no longer applies, and a zero rate on Israeli employment income within an annual ceiling applies to arrivals between 5 November 2025 and 31 December 2026 | Immediate, on the aliyah route |
A residence permit does not itself determine treaty application, account reporting or a bank's acceptance of funds.
| Destination | Treaty with Russia after Decree No. 585 | In the FTS automatic-exchange list | Banking on a Russian passport | Family |
|---|---|---|---|---|
| UAE | Outside the Decree 585 list; the agreement of 17 February 2025 applies in full from 1 January 2026, capping withholding at 10% | Yes | The Russian connection is screened harder | Sponsored by the permit holder |
| Kazakhstan | In force | Yes | Among the easiest; compliance has tightened noticeably | Standard family permits |
| Armenia | In force in full | Yes | The easiest of the ten, on the common EAEU framework | Standard family permits |
| Georgia | None — there has never been a treaty | No | New clients from Russia are examined more closely | Family permits on the holder's ground |
| Turkey | Outside the Decree 585 list — the treaty applies | Yes | — | Spouse and children under 18 are included in the citizenship application |
| Serbia | The 1995 convention is suspended only in respect of Montenegro (item 17 of the decree), so it continues to apply to Serbia | No | A non-resident opens an account on a personal visit; the outcome depends on the bank's ownership group | Reunification, filed only after the principal is approved |
| Cyprus | Suspended — item 27 of the decree | No | Deposits above €100,000 only for a holder of an EU, EEA or Swiss residence permit (art. 5b of Regulation 833/2014) | Reunification |
| Spain | Suspended — item 28 of the decree | No | The same €100,000 deposit rule under art. 5b | Reunification |
| Portugal | Suspended — item 32 of the decree | No | The same €100,000 deposit rule under art. 5b | Reunification; the golden visa covers the family in one application |
| Israel | Outside the Decree 585 list — the treaty applies | Yes | — | Under the Law of Return, with the family |
Treaties, Reporting and Banking
The destinations whose treaties remain in force — Armenia, Kazakhstan, the UAE, Turkey, Israel — are exactly those included in the automatic-exchange list approved by the FTS order of 14 October 2025 No. ED-7-17/883@, which covers 71 states and 9 territories. The European destinations have the opposite combination: Cyprus, Spain and Portugal are listed in Article 1 of Decree No. 585 as items 27, 28 and 32, so the treaty rate at source no longer applies, and none appears in the exchange list. Neither treaty continuity nor exchange-list membership is a benefit on its own: a treaty in force provides relief and a credit, while exchange-list membership makes the account visible to the tax authority of residence, which makes a declared position defensible.
There are two exceptions to this relationship. Georgia has no treaty at all and is not in the exchange list, so double taxation is relieved only by the unilateral rules of the two codes. Serbia retains a treaty in force because item 17 of the decree suspends the 1995 convention with the Federal Republic of Yugoslavia in respect of Montenegro, and Serbia is not named. The convention therefore continues to apply to Serbia, while Serbia is outside the exchange list.
For banking purposes, the ten destinations fall into three groups rather than two. The EAEU pair is the easiest and Serbia is an accessible European exception, where a non-resident opens an account on a personal visit. Georgia and the UAE accept applications but examine the Russian connection closely. For Cyprus, Spain and Portugal the constraint is legal rather than commercial: article 5b of Regulation (EU) No 833/2014 prohibits accepting deposits above €100,000 per credit institution from Russian nationals and residents of Russia, and paragraph 3 lifts that prohibition for a holder of a temporary or permanent residence permit in a member state, an EEA country or Switzerland. The residence permit, rather than the passport, provides access to a European account from the first day, before the naturalisation period is completed.
Three income profiles
| Income profile | Relevant conditions | Tax consequences |
|---|---|---|
| Salary from a Russian employer for remote work | The pay stays Russian-source income under Federal Law No. 389-FZ and is taxed on the 13–22% scale whatever the new residence; what matters is whether the destination taxes it again | Georgia's territorial treatment and the UAE's zero rate result in no additional tax; Armenia at 20%, Kazakhstan at 10–15%, Serbia, Turkey and the EU states tax it as worldwide income of a resident, and relief depends on a treaty in force — which the three European destinations no longer have |
| Dividends from a Russian company | Withholding at source — 15% for a non-resident individual — and whether a treaty gives a reduction and a credit | The UAE caps withholding at 10% from 2026, and Armenia, Kazakhstan, Turkey and Israel keep their treaty relief; in Cyprus, Spain and Portugal the reduction is suspended, so the full domestic rate applies and the credit must be determined under the destination's own rules |
| Passive income earned outside Russia | The destination's own regime, because Russia does not tax this income once residence is lost | Cyprus non-dom applies 0% to dividends and interest for 17 years, Israel exempts foreign income for ten, Georgia is territorial and the UAE has no personal tax at all; Spain adds a wealth tax, and Portugal's IFICI covers neither pensions nor income from blacklisted jurisdictions |
Other Destinations and Immigration Programmes
Relocation involves rules in the country of departure and requirements in the destination. See also the departure and arrival requirements.
- Digital nomads and remote work: Croatia · Italy · Greece and Cyprus · Asia · Indonesia · Latin America · UAE (remote-work)
- Residence permits and residency — Europe: Monaco · Switzerland · Andorra · Gibraltar · Liechtenstein · Channel Islands · Malta (GRP) · Spain · Turkey
- Residence permits and residency — Gulf and Asia: UAE · Singapore · Singapore (GIP/PR) · Hong Kong
- Residence permits and residency — Americas and islands: USA · Mexico · Costa Rica · Paraguay · Uruguay · Mauritius · Bermuda · Cayman Islands
- Citizenship and residence by investment: Residence by investment (overview) · EU citizenship · Portugal (golden visa) · Greece (golden visa) · Malta (citizenship) · Turkey (citizenship) · CBI (overview) · St Kitts and Nevis · Dominica · Grenada · St Lucia · Antigua · Vanuatu · Egypt and Jordan
- Restrictions that relocation alone does not remove: sanctions regimes and restrictions.
Compliance requirements are tightening across all four destinations. Banks ask for proof of the source of funds, tax status and often a local address. Accordingly, a legal basis for residence and local tax status are established first, followed by a bank account and, only then, asset transfers.
Armenia and Kazakhstan are convenient for their proximity, EAEU access, and double-tax treaties in force; Georgia for its territorial tax; the UAE for its zero rate and the updated treaty from 2026. The choice depends on the income structure, banking needs and planning period.
Q/A
Which destinations still give treaty relief on Russian-source payments?
Armenia, Kazakhstan, Turkey and Israel are outside the list in Article 1 of Decree No. 585, so their treaties apply; the UAE is outside it too, and its agreement of 17 February 2025 applies in full from 1 January 2026 with withholding capped at 10%. Cyprus, Spain and Portugal are items 27, 28 and 32 of that list, so the reduced rates at source are frozen. Georgia has no treaty at all, and Serbia keeps one because item 17 suspends the 1995 convention only in respect of Montenegro.
Does being outside the automatic-exchange list help?
The list approved by the FTS order of 14 October 2025 No. ED-7-17/883@ covers 71 states and 9 territories, and Armenia, Kazakhstan, the UAE, Turkey and Israel are in it while Serbia, Georgia, Cyprus, Spain and Portugal are not. Absence from the list removes an automatic flow of account data, not any reporting duty: a currency resident still notifies the tax authority of a foreign account and files cash-flow reports unless more than 183 days a year are spent outside Russia.
Why does a European residence permit matter for banking access before naturalisation?
Because article 5b of Regulation (EU) No 833/2014 prohibits accepting deposits above €100,000 per credit institution from Russian nationals and from natural persons residing in Russia, and paragraph 3 excludes from that prohibition anyone holding the nationality of a member state, an EEA country or Switzerland or a temporary or permanent residence permit in one of them. A first-year permit therefore removes the ceiling, while naturalisation has a timeframe of five to ten years.
What banking and compliance problems do Russians face after relocating — and how are they solved?
Banks apply their own de-risking policies in addition to legal requirements: source-of-funds evidence, a local tax number and address are requested everywhere, with the strictest screening in Georgia and the UAE and the lightest in EAEU states. The sequence is a legal basis to stay, local tax status, a bank account and, only then, asset transfers. Documents are prepared before the funds are transferred.
Can a family with Russian connections still open private banking accounts in Switzerland, Singapore or Dubai?
In law, yes — citizenship alone is not a banking prohibition. In practice, acceptance policies are set by each bank and depend on the quality of the source-of-wealth evidence, screening for sanctioned persons and the applicant's residence circumstances.
What is the safest passport and residence combination for a Russian entrepreneur now?
There is no universally safest combination. The choice depends on banking access, treaty position and sanctions exposure; a second residence that restores normal banking and treaty treatment usually matters more than a second passport.
How do the tax implications of relocating from Russia to the UAE and Singapore compare in 2026?
The UAE path is shorter on personal tax (zero rate; comprehensive treaty in force since 18 July 2025 and applied from 1 January 2026) but thinner on long-term status; the SG path costs more (EP substance; personal top rate — see IRAS — individual income tax rates) but buys a stronger residence and banking narrative.