Concept
Russian private capital operates within a dual coordinate system: RF rules (tax and currency residency, CFC, notifications) and the external circuit (sanctions filters, bank compliance, suspended DTTs). Mistakes arise at the intersection: you can leave perfectly according to Russian rules and remain unbanked by a Western bank—and vice versa. This hub is a map of both circuits.
These two circuits diverge because they are governed by different centers: the Russian one by the Tax Code and currency legislation, the external one by sanctions lists and the risk appetite of specific banks. Solutions here cannot be reduced to a single criterion: a structure impeccable under Russian rules may fail KYC in Europe, while a convenient foreign account may create an undeclared CFC or violate currency restrictions at home. The hub is structured according to this logic: first the Russian circuit, then the external one, and separately—money and structures at their intersection.
If You Are Leaving
Loss of RF tax residency occurs after 183 days outside the country: the rate on Russian income becomes 30% (for dividends—15%), but worldwide income falls out of the Russian tax base. Relocation: Armenia, Kazakhstan, Georgia, UAE—typical first jurisdictions with different tax consequences. Where to go next—see special tax regimes and second citizenship. Don't forget the notification to the Ministry of Internal Affairs about residence permits or passports.
After loss of residency, worldwide income falls out of the Russian tax base, but Russian-source income is taxed at 30%, and foreign tax credit under suspended DTTs no longer helps. Since 2025, certain categories of non-residents—HQPs (highly qualified specialists), remote employees of Russian companies, workers from the EAEU—pay personal income tax on employment income at the same progressive scale of 13–22% as residents. There is no separate exit tax in Russia: tax arises upon disposal of assets, and departure itself is not considered a taxable event for personal income tax. The 183 days are counted for each calendar year separately, so status is lost and regained along with geography. The first jurisdictions—Armenia, Kazakhstan, Georgia, UAE—differ in the main thing: how they view remote work for Russian companies and how quickly they grant local tax residency.
If You Remain a Resident
Foreign infrastructure remains accountable: notifications to the Federal Tax Service about foreign accounts and ODDS (currency residency), CFC declaration with profits from 10 million ₽, and the general framework of CFC regimes if there are multiple residencies. Suspension of DTTs means double taxation on many flows—preferential rates at source no longer work. For historical tails—capital amnesties and voluntary disclosure.
The CFC regime requires two separate actions: notify about all controlled companies regardless of their profit and pay tax on undistributed profit exceeding 10 million ₽ per year. Since 2025, many EU countries have dropped out of automatic exchange with the RF, so for such CFCs the tax authority expects an audit report confirming the profit calculation. For those whose administration costs more than the profit itself, there is a fixed profit regime. The cost of error is high: CFC fines reach 2 million ₽ per company per year, and formal discipline here is more important than fine-tuning optimization.
Structures: Inside and Outside
Inside the RF, the answer to the trust has become the personal and inheritance foundation—with clear boundaries of applicability; the return of holdings home goes through SAR and redomiciliation. Outside—the classics: trusts (adjusted for taxation of beneficiaries from the RF), private foundations and holding structures—all with mandatory verification for sanctions resilience and substance. The RF inheritance circuit—intestate succession and inheritance contract—is in the succession planning hub.
Since 2025, the personal foundation has acquired its own tax profile: a corporate income tax rate of 15% instead of the general 25%, if at least 90% of the foundation's income is passive (dividends, interest, rent, income from the sale of assets). The entry threshold is high: assets from 100 million ₽ (Art. 284.12 of the Tax Code of the RF, Ch. 50.1 of the Civil Code of the RF). This is a tool for already formed capital; it will not work as a startup wrapper. Outside, trusts and foundations coexist in parallel—adjusted for taxation of beneficiaries who are RF residents and mandatory verification for substance.
Money and Accounts
A personal account abroad runs into the origin of funds and citizenship: the list of countries unfriendly to the RF works both ways. Working corridors: CNY payments and China, Freedom Bank in Kazakhstan, Collect & Pay in AIFC. Unblocking frozen assets—through Euroclear/Clearstream licenses and OFAC procedures.
Unblocking through asset exchange under Decree No. 844 mostly remained in 2024: the "Investment Chamber" conducted two rounds, non-residents bought out securities of Russians from type "C" accounts, the limit per investor—100 thousand ₽. Of the approximately 35 billion ₽ declared for exchange, about 8 billion ₽ were actually bought out, roughly a quarter. No new mass rounds on this channel have been announced since then (requires verification), so the working path today is individual Euroclear and Clearstream licenses and OFAC procedures. In parallel, investors still have type "C" accounts, where frozen coupons and dividends are credited; these funds can only be disposed of within a narrow perimeter of permitted operations.
Questions and Answers
I left and became a non-resident—do I still need to report foreign accounts?
If you spent more than 183 days outside the RF in a year, the obligations of a currency resident for notifications and ODDS are lifted for that year. But status is counted for each year separately: one long visit home—and reporting returns.
DTTs are suspended—what does this mean in practice?
There are no preferential rates at source: dividends, interest, and royalties between the RF and "unfriendly" countries are taxed at the domestic rates of both sides, credit works fragmentarily. Flows through such pairs of jurisdictions need to be reassembled, not wait for the restoration of agreements.
Is a personal foundation in the RF a full replacement for a trust?
For assets inside the RF—a working tool for succession and capital separation. For international capital—no: outside the RF its recognition is limited, and the sanctions context makes the foundation's foreign assets vulnerable. A typical solution is a two-circuit structure: a personal foundation inside, a trust or foundation outside.