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.
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. Russian domestic law ignores the centre of vital interests that Article 4 of the OECD Model Convention uses to break ties, and counts only the calendar. The treaty tie-breaker that might otherwise resolve a dual claim is, for unfriendly states, suspended in any case. Status can be lost by spending most of the year abroad and regained the next.
⚙️ 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 outside the Russian base entirely. The trade-off is the rate. The default for a non-resident is 30% with no deductions, against a resident's progressive 13–22% scale where the usual deductions apply. A few carve-outs soften specific income: dividends from Russian companies are taxed at 15%, highly qualified specialists are taxed on the resident scale from day one, and remote pay from a Russian employer now follows the resident scale too (see below). On ordinary Russian-source income, though, a non-resident usually pays more, not less.
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.
Currency Residency Is a Separate Status
Tax residency and currency residency sit in different statutes and do not move together. A Russian citizen stays a currency resident by virtue of citizenship, whatever the day count. What the calendar changes is the reporting load: a citizen who spends more than 183 days of the year abroad is released from notifying the tax authority about opening or closing foreign accounts, from the annual cash-flow statement, and from the restrictions on crediting funds to those accounts (Article 12 of Law 173-FZ, as amended in 2019). The relief is conditional: drop back below 183 days in a later year and the full set of duties returns.
Treaties No Longer Soften the Exit
Leaving once meant leaning on a double tax treaty: the new country of residence taxed worldwide income, and the treaty capped what Russia could take at source. Since August 2023, Decree No. 585 has suspended the core articles of treaties with the states Russia treats as unfriendly, and several of those countries have suspended their side in turn: the United States from August 2024, the United Kingdom in full from April 2025. For income that stays Russian-source after departure, domestic rates now apply without treaty relief: 15% on dividends from Russian companies, 30% on most other payments to a non-resident. Whether the new country credits that Russian tax depends on its own law, not on a treaty that is currently dormant.
What Departure Does Not Switch Off
Becoming a non-resident narrows the Russian base; it does not close every Russian file. Controlled Foreign Company duties follow tax residency, so they ease only once you are genuinely non-resident for the full year; for the transition year, while the calendar still counts you as a resident, CFC notifications and profit rules continue to apply. Assets left inside Russia keep their Russian source. Russia itself levies no general exit tax on departure, but the jurisdiction you move to may tax accrued gains on the way in or out, so the destination's own rules deserve a look before the move rather than after.
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.