Concept
Capital amnesty is a state offer to declare foreign assets, accounts, and companies in exchange for immunity from liability for past tax and currency violations. In Russia, this mechanism operated in four waves from 2015 to 2023 and was based on a single law—Federal Law No. 140-FZ of June 8, 2015, on voluntary declaration by individuals of assets and bank accounts. Instead of prosecuting owners of opaque structures, the state opened a window for them to emerge from the shadows on pre-announced terms.
Why It Was Needed
The amnesty did not appear in a vacuum. From 2015, Russia launched de-offshorization: the law on controlled foreign companies required residents to disclose and tax profits of foreign structures, while joining the automatic CRS exchange stripped offshore accounts of their former invisibility. Owners of foreign assets faced a choice—bring structures into compliance with new rules or live with the risk of additional assessments and criminal prosecution for past periods. The special declaration offered a third option: disclose assets and close the past.
Four Waves
The first stage ran from July 1, 2015, to June 30, 2016, and allowed declaration of property, foreign accounts, and controlled companies. The second stage (March 1, 2018 – February 28, 2019) added the ability to declare accounts already closed at that time. The third stage (June 1, 2019 – February 29, 2020) proved the most demanding: guarantees were given only to those who transferred money to Russia and re-registered foreign companies in special administrative regions on Russky Island or Oktyabrsky Island. The fourth stage started on March 9, 2022, against the backdrop of sanctions and concluded on March 1, 2023.
What the Special Declaration Provided
The main value of the amnesty was guarantees. Filing a special declaration with the tax authority exempted the declarant and related persons from tax, administrative, and certain criminal liability for violations related to declared assets—primarily under tax and currency articles. The declaration itself received confidential status: it could not be used as evidence in cases concerning violations committed before the filing date. Operations to transfer assets and funds reflected in the declaration were recognized as performed without violation of currency legislation.
Protection was not unlimited. It extended only to what was explicitly stated in the declaration and did not cover future periods or acts unrelated to declared assets. The amnesty did not cancel the obligation to pay taxes going forward—it merely drew a line under the past.
Legal Framework and Guarantees
Legally, the entire structure rested on a single law—140-FZ of June 8, 2015—and coordinated amendments to the Tax and Criminal Codes. The declarant was exempted from criminal liability under Article 193, parts one and two of Article 194, Articles 198, 199, 199.1, and 199.2 of the Criminal Code—covering currency operations, customs payments, and tax evasion—as well as from administrative and tax liability for acts directly related to declared property. Information from the special declaration received tax secrecy status: it could not be requested from the tax authority and used as evidence. Filing the declaration itself did not create an obligation to pay tax on disclosed assets. For the first three stages, the amnesty covered acts committed before January 1, 2015; for the fourth, the cutoff date shifted to January 1, 2022.
How It Worked in Practice
A typical participant was an owner of a foreign company with an account and real estate abroad who, by the time CFC rules launched and Russia joined the automatic CRS exchange, realized that former opacity no longer justified itself. The special declaration allowed disclosure of the entire ownership chain, transfer of assets to the Russian perimeter, and removal of the risk of additional assessments for past years. The amnesty went hand in hand with de-offshorization: parallel tax-free CFC liquidation operated, where the beneficiary received property of the liquidated foreign company without personal income tax, and from the third stage, redomiciliation of structures to special administrative regions on Russky Island and Oktyabrsky Island was added.
The sequence was clear: declare the company and account, if necessary transfer money to a Russian bank, liquidate or re-register the structure—and receive written state guarantees. For someone with a long offshore history, this provided an opportunity to close the past at once, on pre-announced terms.
How Russian Amnesty Differed from Foreign Ones
Most foreign amnesties are structured as paid legalization. The Italian scudo fiscale in its 2009 version taxed returned assets with a flat 5 percent levy—about 80 billion euros were declared, the budget received around 4 billion. Indonesia's 2016 amnesty charged a redemption payment at a graduated rate and collected about $9.6 billion. The American OVDP required payment of back taxes and penalties for past periods. The Russian model priced differently: the special declaration itself was not taxed, and the state did not levy a percentage on disclosed capital. The price for guarantees was disclosure, and at certain stages—return of money to the country, foreign account reporting, and company re-registration in SARs.
How It Ended
The fourth stage concluded in March 2023, and no new wave has been announced since. Each successive campaign gathered an increasingly narrow circle of participants: by 2022, most who wanted and could legalize had already done so, and for the remainder, capital return to Russia was complicated by sanctions and asset freezes. For private owners, the amnesty remains a tool with a specific expiration date and tied to an announced window.
What's Next
No new wave has been announced after March 2023. The context had changed by that point: after 2022, Russia suspended automatic tax information exchange with a number of unfriendly jurisdictions, and the main channel for "landing" assets became special administrative regions and business redomiciliation inside the country. For private individuals, the trajectory more often went through tax residency change than through disclosure. The idea of a fifth amnesty periodically surfaces in discussions, but the linkage of previous stages to repatriation and SARs shows the direction: the state is more likely to offer tools for transferring structures to the Russian perimeter than to repeat the soft 2015 format (requires verification).
Q/A
Can a special declaration be filed now?
No. Federal Law No. 140-FZ gave the fourth stage a closed filing window from 14 March 2022 through 28 February 2023. The statute contains no standing filing mechanism after that date; a new stage would require legislation, so the former form cannot be used as current protection.
Did the amnesty automatically erase arrears and tax on the assets?
No. Filing did not itself impose a levy on the disclosed capital, but it did not cancel every tax obligation either. The statute granted relief from specifically listed liabilities for past acts connected with disclosed items, subject to conditions; later periods and ordinary ongoing taxation remained.
Did the guarantees cover all of an owner’s foreign property?
No. Article 4 confines protection to the property, accounts, cash, controlled foreign companies and operations described in the declaration. For interests in Russian or foreign entities and controlled foreign companies, protection is additionally capped by their asset value at filing; omitted property received no protection.
Could the declaration be used against the declarant?
Generally no. The filing and its contents cannot be used as evidence in criminal, administrative or tax-offence proceedings and are protected as tax secrecy. The declarant may, however, choose to submit a copy as evidence; the authority may not refuse to add that copy to the case.
Was the cut-off date the same for all four stages?
No. Article 4(13) links protection to acts before 1 January 2015 for stage one, 1 January 2018 for stage two, 1 January 2019 for stage three and 1 January 2022 for stage four. The first stage’s cut-off therefore cannot be applied across all four campaigns.