Concept
Russian tax residency turns on the number of days spent in the country; citizenship and registration do not affect it. Leave for long enough and you stop being a tax resident: your rate, your tax base, and your right to deductions all shift, even though the duty to pay itself does not disappear. The mechanics are worth understanding before departure, because the costly mistakes are made in hindsight, by selling an apartment or booking income in the wrong calendar year.
Short answer. Russia decides an individual's tax residence by one mechanical test: 183 or more days of physical presence within 12 consecutive months — there is no statutory ties or centre-of-interests test for individuals, so losing residence means failing the day count, not proving a new life elsewhere.
The consequences outlive the departure: non-residents pay 30% on Russian-source income with no deductions (15% on dividends), while residents face the 2025 five-step scale of 13/15/18/20/22% — and two traps recur: selling Russian real estate as a non-resident within the minimum holding period (30% on the full price, with no deduction for expenses) and remote work for a Russian employer, which under the post-389-FZ rules can keep employment income Russian-sourced even after relocation.
Currency residency under Federal Law 173-FZ is a separate status that follows its own logic, and Russian CFC obligations attach while tax residence lasts and close with final filings for the last calendar year in which the person still counted as a resident, not on the day of departure. The exit works as a sequence: fix the day count, settle Russian-source income, time property disposals, close CFC filings.
The 183-Day Rule—and Only Days
A Russian tax resident is someone who has spent at least 183 days in the country across 12 consecutive months; for a given tax period, the final status turns on the day count in that calendar year. Unlike the tie-breaker in Article 4 of the OECD Model Convention, Russian domestic law does not look at the centre of vital interests—only at the calendar. So status can be lost simply by spending most of the year abroad, and regained the next year.
What Changes for a Non-Resident
A non-resident pays personal income tax only on income from sources in Russia—foreign income falls outside the Russian base entirely. The price is the rate: the default for a non-resident is 30%, with no deductions or reliefs, whereas a resident is taxed on the progressive 13–22% scale and may claim deductions. Individual income types carry their own rates: a non-resident pays 15% on dividends from Russian companies. The paradox is that on Russian-source income a non-resident often pays more than they would as a resident.
What Income Remains Taxable in Russia
After the loss of residency, only a closed set of income falls under Russian tax: dividends and interest from Russian companies and banks, rent on real estate in Russia, income from the sale of Russian real estate, shares and participations, pay for work actually performed in Russia, and pay from a Russian employer under a remote-work contract (see the exception below); pay for work performed abroad under an ordinary, non-remote contract is foreign-source income (Art. 208(3)(6) of the Tax Code). The rates differ: 15% on dividends and on interest on deposits in Russian banks, and the base 30% on most of the rest. Anything earned outside Russia and unconnected to a Russian source is not counted at all.
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 how it was acquired), both residents and non-residents are exempt from personal income tax—a key relief 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, with no reduction for expenses and no deduction—many times more than a resident. So it makes sense to sell property either while you are still a resident or already beyond the minimum holding period.
Exception: Remote Work for a Russian Employer
Since 2024, remuneration of remote workers under employment contracts with Russian companies has been taxed on the resident progressive scale regardless of tax status: 13% up to 2.4 million rubles per year, 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 by itself does not turn a salary from a Russian employer into "foreign" income. From 1 January 2026 this does not help a person who held foreign-agent status on at least one day of the tax year: their income is taxed at 30%, and neither the 15% dividend rate nor the remote-work scale applies (Art. 224(3), (3.1) and (6) of the Tax Code as amended by Federal Law No. 425-FZ of 28 November 2025).
Double Tax Treaties Are Suspended
Previously a non-resident could rely on a double tax treaty (DTT): it lowered the Russian withholding rate at source on dividends, interest and royalties and allowed the tax paid to be credited at home. Since August 2023, Decree No. 585 and then Law No. 598-FZ have suspended the core provisions of the treaties with "unfriendly" countries—almost the entire European Union, the United Kingdom, the United States and Japan. Treaty relief rates no longer apply to them: tax is withheld at source at the Russian domestic rate, and how to credit it in the country of residence is a matter for that country's own law alone. In practice this often means double taxation: Russia withholds at source, and the new country may tax the same income under its own rules.
Currency Residency Is a Separate Regime
Tax residency and currency residency are easy to confuse, though they are counted differently. A Russian citizen remains a currency resident permanently—the status is tied to citizenship, not to days. But someone who spends more than 183 days a year abroad is relieved of part of their currency obligations: no need to notify the FTS of opening or closing foreign accounts or to file the cash-flow report. At the same time, the ban on certain currency transactions between residents remains. The confusion is costly: penalties for an unfiled report reach even those who have long lived abroad and no longer think about the Russian rules.
How Days Are Counted
No application to "lose residency" needs to be filed—the tax authority determines status itself, at the end of the calendar year. Days are counted by actual presence: the day of arrival and the day of departure both count as spent in Russia, and trips abroad for short-term (less than six months) treatment or study do not interrupt residency (Art. 207(2) of the Tax Code). Presence is confirmed by passport stamps, tickets and migration cards. If during the year you received Russian income and changed status, personal income tax is recalculated at year-end: the employer does so at source, everything else through the 3-NDFL return.
What to Do
Plan the year by days and work out in advance what status you will hold on December 31. Tie asset transactions to that status. Separately check currency residency, foreign-account reporting and the CFC rules—each runs on its own test: currency duties follow citizenship and days abroad, while CFC duties follow Russian tax residence for each calendar year. And, of course, establish new tax residency where you actually live. How the Russian exit half meshes with the entry rules of a particular destination is shown in the relocation matrix.
Losing Russian residency changes the tax regime: only income from sources in Russia now falls under Russian tax, but at 30% and without deductions. The real gain appears only once the main income has truly become foreign and transactions are planned around the calendar.
Q/A
Does a non-resident pay less, since foreign income is outside the base?
Not necessarily. Foreign income does fall outside the Russian base entirely, but on Russian-source income the rate rises to 30% with no deductions or reliefs, whereas a resident pays on the five-step scale from 13% to 22%. On dividends from Russian companies the non-resident rate is 15%. On Russian-source income a non-resident often pays more than they would as a resident.
I sold an apartment in the year I left — at what rate is the tax calculated?
Status is fixed on 31 December of the year of the transaction, not on its date. If the property has been owned longer than the minimum holding period — three or five years depending on how it was acquired — both residents and non-residents are exempt from personal income tax. If the period has not been met, a non-resident pays 30% on the entire sale amount, with no reduction for expenses and no deduction. So it makes sense to close the deal either while still a resident or already beyond the minimum holding period.
I have left — has my salary from Russia become foreign income?
Not if the job is formalised as remote work for a Russian employer. Since 2024, remuneration of remote workers under employment contracts with Russian companies has been taxed on the resident progressive scale regardless of tax status: 13% up to 2.4 million rubles per year, then 15/18/20/22% on the five-tier 2025 scale. Since 2025 the same approach has been extended to certain contractors working through Russian internet platforms. Pay for work actually performed abroad under an ordinary, non-remote employment contract is foreign-source income (Art. 208(3)(6) of the Tax Code).
Is currency residency lost together with tax residency?
No. A Russian citizen remains a currency resident permanently — the status is tied to citizenship, not to days. But someone who spends more than 183 days a year abroad is relieved of part of those obligations: no need to notify the FTS of opening or closing foreign accounts or to file the cash-flow report. The ban on certain currency transactions between residents remains in place.
What happens to my Russian CFC obligations when I become a Singapore tax resident?
Russian CFC duties — participation notices and annual CFC declarations — attach to Russian tax residence, not to citizenship: while the 183-day count still holds, they continue even from Singapore; they close with final filings for the last calendar year in which the person still counted as a Russian resident, and stop from the following year.
There is no mid-year cessation date: status is settled for the whole calendar year (Art. 216 of the Tax Code of the Russian Federation; Federal Tax Service letter No. ШЮ-4-17/16342@ of 27 December 2023), and a company is a CFC only while its controlling person is a Russian tax resident (Art. 25.13(1)(2)).
The final filings: the CFC notification is due by 30 April of the year following that tax period (Art. 25.14(2)), CFC profit is deemed received on 31 December of the year following the year in which the CFC's financial year ends (Art. 223(1.1)) and is declared on the 3-NDFL return; a missed notification costs RUB 500,000 per CFC (Art. 129.6(1)). Singapore does not tax an individual's foreign passive income on entry. The current treaty status between Russia and Singapore is covered at Suspension of Tax Treaties by Russia.