Any decision about money with a Russian element passes a double check in 2026. The first set of rules comes from the Tax Code, currency control legislation, and presidential decrees; the second from sanctions lists, foreign bank compliance, and suspended tax treaties. The cost of error has grown on both sides: at home, a progressive personal income tax of up to 22% and per-item fines for CFC and currency violations; outside, asset freezes and account refusals triggered by the passport itself.
Some restrictions have moved toward relaxation: the Central Bank lifted limits on transfers abroad, a new tax treaty with the UAE is in effect, and the digital ruble is entering mass rollout. The foundation is unchanged: three independent Russian statuses — tax, currency, and migration — with the sanctions circuit layered on top.
Concept
Russian private capital operates in 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: it is possible to leave impeccably under Russian rules and remain an unbankable client for a Western institution — or to build convenient foreign infrastructure and discover an undeclared CFC with currency fines back home.
The two circuits are governed by different centers and change at different speeds: the Russian one through Tax Code amendments and decrees, the external one through sanctions packages and the risk appetite of specific banks. Every decision therefore gets checked twice: a structure impeccable under Russian rules may fail KYC in Europe, while a convenient foreign account may violate currency restrictions at home. The order of checks is therefore fixed: first the Russian statuses, then structures, money, and routes at their intersection.
Tax Residency and the Progressive Scale
Residency is arithmetic: 183 days in Russia within 12 consecutive months, with the final status fixed by the calendar year. Family, real estate, and center of vital interests play no role in domestic law — those criteria live only in the DTTs, most of which are suspended. Short trips abroad for medical treatment or education (up to six months) count as Russian days. The counting mechanics and borderline scenarios of the departure year are covered in the article on losing Russian tax residency.
Since 2025 residents pay under a five-band scale: 13% up to 2.4 million ₽ of annual income, then 15% up to 5 million, 18% up to 20 million, 20% up to 50 million, and 22% above; the higher rate applies only to the excess, and the thresholds did not change for 2026 (Article 224 of the RF Tax Code, Law No. 176-FZ). Passive income of residents — dividends, interest, sales of property and securities — follows a separate 13/15% scale with a 2.4 million ₽ threshold; details in the guide to Russian dividend taxation.
A non-resident is taxed only on Russian-source income, at hard rates: 30% as the general rate, 15% on dividends from Russian companies. The classic exit trap is a property sale: a non-resident pays 30% on the full price with no deduction for acquisition costs. The rescue is the minimum holding period (three or five years depending on how the asset was acquired) — since 2019 that exemption applies to non-residents as well.
The second trap was closed by the legislator: since 2024, remuneration of remote employees of Russian employers counts as Russian-source income and is taxed at resident-scale rates regardless of status (sub-clause 6.2 of clause 1, Article 208 of the RF Tax Code, Law No. 389-FZ); from 2025 the same applies to contractors working through the Russian segment of the internet (sub-clause 6.3), with the 13–22% scale extended to these categories of non-residents (clause 3.1, Article 224, Law No. 176-FZ). There is no separate exit tax: departure itself is no taxable event — tax arises on the disposal of assets.
Currency Status: Accounts, Reporting, Limits
Currency residency is built separately from tax residency: currency residents are all RF citizens plus foreigners with a Russian residence permit, and the status survives departure. Only the reporting softens: a resident who spends more than 183 days outside the RF in a calendar year is released from account notifications and cash-flow reports (ODDS) for that year; foreign-currency transactions between two such "departed" residents are also permitted.
For those living in Russia the discipline is complete: notify the Federal Tax Service of opening, closing, or changing the details of a foreign account within one month, and file the ODDS by June 1 of the following year.
The small-account ODDS exemption is tied to the FTS auto-exchange list: no report is due if the account country automatically exchanges information with the RF and annual flows stay within 600 thousand ₽. That list is shrinking: FTS Order No. ED-7-17/916@ of 30.10.2024 removed 26 jurisdictions from the list, leaving 63 states and 12 territories in it, and Order No. ED-7-17/883@ of 14.10.2025 removed Bermuda, the BVI, Gibraltar, and Turks and Caicos. Accounts in the excluded jurisdictions fall under full reporting, and a range of credits to them becomes an illegal currency operation with a fine of 20–40% of the amount (part 1, Article 15.25 of the RF Administrative Code). Forms, deadlines, and practice — in the foreign account reporting guide.
Outbound limits are mostly gone: from December 8, 2025 the Central Bank cancelled the $1 million per month ceiling on transfers abroad for RF citizens and individuals from friendly states, including the $10 thousand limit for money transfer systems. Targeted bans remain for non-residents from unfriendly states and roll over in six-month cycles (currently until June 7, 2026). Lifting the limits cancels neither Russian reporting nor the receiving bank's compliance questions.
Migration duties exist apart from both statuses: a citizen must notify the Ministry of Internal Affairs of a second citizenship or residence permit within 60 days (for those abroad — within 60 days of first entering the RF); concealment triggers criminal liability under Article 330.2 of the Criminal Code. The procedure — in the article on the MVD notification.
CFC: Notifications, Tax, the Fixed-Profit Regime
A foreign company, foundation, or trust controlled by a Russian tax resident is a CFC with two separate duties: notify and pay. The participation notification is due within three months of acquiring a stake above 10%; the annual CFC notification — by April 30, regardless of the company's profit or activity. Tax arises when the CFC's undistributed profit exceeds 10 million ₽ per year.
Fines are per item: 500 thousand ₽ for each unfiled CFC notification (Article 129.6 of the RF Tax Code) plus up to 1 million ₽ for documents left unsubmitted after a demand — formal discipline here matters more than fine-tuned optimization. The base mechanics — in the CFC article; how the Russian regime compares with other countries' CFC rules — in the CFC master guide.
Proving profit has become more expensive: for CFCs from jurisdictions outside the auto-exchange list, financial statements are accepted only with an audit opinion. The alternative for structures that are costly to administer is the fixed-profit regime: since 2025 the imputed profit is 27,990,000 ₽ for one CFC (about 5 million ₽ of annual personal income tax), 52,718,000 ₽ for two, rising to a cap of 120,899,900 ₽ for five or more (about 25 million ₽ of tax); the regime binds for at least five years (Article 227.2 of the RF Tax Code). Before 2025 the fixed option cost about 5 million ₽ regardless of the number of companies — owners of several CFCs should redo the math.
Relocation removes CFC duties only for the years of non-residency: the status is tested by calendar-year results, and a single "return" year restores both the notifications and the tax. Trusts and foreign foundations sit inside the same perimeter as structures without legal personality; the consequences for Russian settlors and beneficiaries — in the article on trust taxation for RF residents.
DTTs: What Is Suspended and What Survives
By Decree No. 585 of August 8, 2023 Russia suspended the substantive articles of its DTTs with 38 "unfriendly" states: reduced withholding rates on dividends, interest, and royalties stopped working, as did the permanent establishment rules. The United States mirrored the suspension of its side of the 1992 convention from August 16, 2024. The result is double taxation of many cross-border flows at both sides' domestic rates.
The treaties formally remain in force, and three blocks continue to operate: the elimination-of-double-taxation articles — which is why the foreign tax credit for Russian residents survives, as the Finance Ministry has confirmed in guidance — plus exchange of information and the mutual agreement procedure. Actual exchange with most of these states is frozen, yet the legal basis stands. An article-by-article map of the suspension and the treaties still working with friendly jurisdictions — in the DTT suspension review. The fresh item: the treaty with the UAE was signed on 17 February 2025, ratified by Federal Law No. 189-FZ of 07.07.2025 and entered into force on 18 July 2025 — the first full treaty with the main jurisdiction of Russian relocation.
Structures: Personal Foundation, SAR, External Wrappers
Inside the RF, the answer to the trust is the personal foundation (Chapter 50.1 of the Civil Code): the founder transfers assets worth at least 100 million ₽ during their lifetime, and the charter defines beneficiaries and payout conditions. Since 2025 the foundation has its own tax profile: a 15% profit tax rate instead of the general 25% where passive income makes up at least 90% (Article 284.12 of the RF Tax Code), and during the founder's lifetime distributions to the founder and to close relatives who are Russian tax residents are exempt from personal income tax (Article 217(18.2) of the RF Tax Code).
It is a tool for capital already formed; it does not work as a startup wrapper. Scope, limits, and succession mechanics — in the personal foundation article.
Bringing holdings home runs through the SARs — the special administrative regions on Oktyabrsky Island (Kaliningrad) and Russky Island (Primorye). A redomiciled company obtains international status, and with real presence — an office, staff, and investments from 300 million ₽ — access to the reduced rates of the international holding company regime, whose conditions are set by Article 284.10 of the RF Tax Code. Foreign personal foundations relocate there as well. Procedure and pitfalls — in the SAR and redomiciliation guide.
Outside, trusts, private foundations, and holding companies keep working — subject to two mandatory checks: tax (CFC status, taxation of RF-resident beneficiaries) and sanctions. Which architecture survives blockings and bank switches — in the article on sanctions-resilient structures.
The Succession Circuit
Russian succession law is tougher on the owner of structures than it looks: the compulsory share of disabled heirs operates against any will, and the intestate succession order kicks in more often than families plan. Targeted transfers are made by will, by an inheritance contract with lifetime conditions, and by an inheritance foundation; the personal foundation solves the same task during the founder's lifetime. The international part — conflicts of law, foreign assets, and blocked securities inside the estate — is gathered in the succession planning hub; marital property questions — in the family hub.
Money: Payment Routes and Unblocking
The payment circuit is defined by sanctions: the largest Russian banks are cut off from SWIFT and blocked in dollars and euros, so routes are built through friendly currencies and intermediaries. Working directions in 2026: CNY settlements and payments through China, adjusted for Chinese banks' caution about secondary sanctions; Kazakhstan — from an account at Freedom Bank to the Collect & Pay route in the AIFC; for retail amounts, transfer services such as KoronaPay.
The reading order for the sanctions cluster — lists, screening, goods restrictions — is set by the sanctions map, while the list of states unfriendly to the RF explains where the two-way restrictions come from. Crypto has taken the niche of a cross-border channel: mining was legalized in late 2024 and foreign trade settlements in crypto are allowed within an experimental legal regime, yet for private capital it remains a route with sanctions and compliance risks at both ends. The state's own line is the digital ruble: from September 1, 2026 the largest banks are required to run operations with it, with the rest joining in stages through 2028; the CBDC context — in the overview of central bank digital currencies.
Assets frozen in Euroclear and Clearstream return slowly: the working path is individual licenses from the Belgian and Luxembourg treasuries and OFAC procedures; the mechanics — in the Euroclear and Clearstream article. The asset swap under Decree No. 844 largely stayed in 2024: the Investment Chamber ran two rounds with a 100 thousand ₽ per-investor limit, about 8 of the declared ~35 billion ₽ was actually bought out, and no new rounds have been announced since. In parallel, non-residents accumulate type "C" accounts holding frozen coupons and dividends — disposal is confined to a narrow perimeter of permitted operations.
Exit Routes
The typical 2022–2026 trajectory has two steps: a quick-landing country (Armenia, Georgia, Kazakhstan, Serbia, Turkey), then a long-horizon jurisdiction. First-step scenarios are collected in the guide to relocation from Russia; endpoint comparison across taxes, banking, and residence permits — in the relocation matrix. For capital, the main choice runs between the Emirates and Singapore: the UAE vs Singapore comparison weighs tax regimes, banks, and the cost of presence. Investment migration for Russian applicants has narrowed: the EU closed most golden visa programs and the remaining ones apply enhanced screening — the current map is in the review of programs for Russian applicants.
Historical tails close separately: the four stages of the capital amnesty ended in February 2023, no new window has opened since, and undeclared history is now handled with standard tools — amended returns and voluntary disclosure. What the amnesty delivered and whom its guarantees still protect — in the capital amnesty article.
Typical Combinations
The departed founder: non-residency removes Russian personal income tax on worldwide income and the CFC duties, leaving 30% (15% on dividends) on Russian-source income, the currency status, and the MVD notification upon obtaining a residence permit. The standard build: tax residency in the UAE or another special regime, accounts in two jurisdictions, and a source-of-wealth file assembled in advance for bank KYC.
The remaining resident with a foreign portfolio: the 13–22% scale on worldwide income, CFC notifications, an ODDS for every account, and audit opinions for European companies. The economics improve with the CFC fixed-profit regime at large profits and moving infrastructure into auto-exchange jurisdictions.
Returning capital home: redomiciling the holding into a SAR plus a personal foundation for family assets — the combination covers both the tax profile (the reduced IHC rates and the foundation's 15%) and succession. The price: real presence in the SAR and the foundation's 100 million ₽ threshold.
Q/A
I left and became a non-resident — do I still have to report foreign accounts?
A person who spends more than 183 days outside the RF in a year is released from the currency resident's notification and ODDS duties for that year. The status is counted separately for each year: one long visit home, and the reporting returns.
The DTTs are suspended — what does that mean in practice?
There are no reduced withholding rates: dividends, interest, and royalties between the RF and "unfriendly" states are taxed at both sides' domestic rates. The credit for Russian residents survives because the elimination-of-double-taxation articles continue to operate. Flows through such jurisdiction pairs have to be reassembled around the new rates — waiting for the treaties to be restored is unrealistic within a planning horizon.
The $1 million limit is gone — can money now be transferred abroad freely?
Since December 2025 a transfer of one's own funds to one's own foreign account is no longer capped by the Central Bank. Three other filters still work: the FTS account notification and ODDS for those living in Russia, the rules on credits to accounts in countries outside auto-exchange, and the receiving bank's compliance with its source-of-funds questions. A foreign bank's refusal occurs more often than a claim from the Russian regulator.
I left, yet I work remotely for a Russian company — at what rate am I taxed?
At the resident 13–22% scale regardless of tax status: since 2024 the remuneration of remote employees of Russian employers is classed as Russian-source income, and the employer withholds the tax. A second tax may arise in the country of residence — whether the Russian tax is creditable depends on that country having a working treaty with the RF.
Is a personal foundation in the RF a full replacement for a trust?
For assets inside the RF — a working tool for succession and separating capital. For international capital — no: its recognition outside the RF is limited, and the sanctions context makes the foundation's foreign assets vulnerable. The typical solution is a two-circuit structure: a personal foundation inside, a trust or foundation outside.