Concept
Russian tax residency is based on the number of days spent in the country; neither citizenship nor registration affects it. When a person leaves for an extended period, they cease to be a tax resident, and their personal income tax rate, tax base, and right to deductions change, although the obligation to pay tax itself does not disappear. It is important to understand the mechanics before departure: the main mistakes are made retroactively—by selling an apartment or receiving income in the wrong calendar year.
The 183-Day Rule—and Only Days
A Russian tax resident is someone who has spent at least 183 days in the country during 12 consecutive months. For a specific tax period, the final status is determined by the number of days in the calendar year. Unlike the tie-breaker under Article 4 of the OECD Model Convention, Russian domestic law does not look at the center of vital interests—only at the calendar. Therefore, status can be lost simply by spending most of the year abroad, and can be regained the following year.
⚙️ Status is calculated at the end of the calendar year; at the time of the transaction itself, it is not yet determined. The same person can be a resident in one year and a non-resident the next—the tax authority counts days retrospectively.
What Changes for a Non-Resident
A non-resident pays personal income tax only on income from sources in Russia—foreign income falls completely outside the Russian tax base. But this comes at the cost of the rate: the basic rate for a non-resident is 30% with no deductions whatsoever, whereas a resident is taxed on a progressive scale from 13% to 22% and is entitled to apply deductions. In other words, a non-resident often pays more, not less, on Russian-source income.
Real Estate Sales—the Main Trap
Here, status is fixed on December 31 of the year of the transaction. If the property has been owned longer than the minimum holding period (three or five years depending on the basis of acquisition), both residents and non-residents are exempt from personal income tax—this is a key benefit that was extended to non-residents in 2019. But if the period has not been met, a non-resident pays 30% on the entire sale amount without reduction for expenses and without deduction—many times more than a resident. Therefore, it makes sense to sell property either while you are still a resident or already beyond the minimum holding period.
💡 The worst scenario is to sell real estate as a non-resident and within the minimum holding period: 30% on the full price. The best is to wait out the minimum period, then status no longer matters.
Exception: Remote Work for a Russian Employer
Since 2024, remuneration of remote workers under employment contracts with Russian companies has been taxed at the resident progressive scale regardless of tax status: 13% up to 2.4 million rubles per year and then 15/18/20/22% on the five-tier 2025 scale. Since 2025, a similar approach has been extended to certain contractors working through Russian internet platforms. In other words, departure itself does not turn salary from a Russian employer into "foreign" income.
What to Do
Plan the year by days and calculate in advance what status you will have on December 31. Tie asset transactions to this status. Separately verify currency residency and reporting on foreign accounts, as well as CFC rules—these are independent regimes that do not depend on tax residency. And, of course, establish new tax residency where you actually live.
💡 Loss of Russian residency changes the tax regime: only income from sources in Russia falls under Russian tax, but at a 30% rate and without deductions. Real savings appear only when the main income has truly become foreign and transactions are planned according to the calendar.
This material is for informational purposes, reflects the norms of the Russian Tax Code as of the date of preparation, and is an expert overview, not individual tax advice. Rules and rates should be verified for specific situations.
Key factual claims
- A Russian tax resident is someone who has spent at least 183 days in the country during 12 consecutive months.
- Status is fixed on December 31 of the year of the transaction.
- Plan the year by days and calculate in advance what status you will have on December 31.
- Related links: Tax Residency: 183 Days · UAE tax residency · Foreign Account and FTS Notification · CFC (Controlled Foreign Companies) · Georgia: Territorial Tax · Unfriendly Countries for Russia · Federal Tax Service of Russia