Russia taxes residents on worldwide income and non-residents on Russia-source income only. Russia operates a hybrid assessment approach: employer withholding settles most wage-earner liability without a filing requirement, while other taxpayers (including those with foreign-source income or CFC obligations) self-file, with the Federal Tax Service conducting post-filing review.
The Russian tax year is the calendar year. The individual filing deadline is 30 April of the following year for taxpayers required to file; the payment deadline (where a balance is due) is 15 July.
25% (increased from 20% effective 2025; reduced 20% band retained for qualifying small businesses; 5% for IT companies).
Progressive 13% to 22% (13% up to RUB 2.4m, rising in steps to 22% above RUB 50m); a separate 30% rate applies to individuals with 'foreign agent' status.
22% standard, effective 1 January 2026 (raised from 20%); reduced 10% rate for essential goods (food, children's products, medicines); 5%/7% preferential rates for simplified-system taxpayers.
Under Article 207 of the Russian Tax Code, an individual is a Russian tax resident if physically present in Russia for 183 days or more within any rolling 12-month period (not necessarily the calendar year); days of arrival and departure both count. Russian organizations are always tax residents; a foreign organization can also become a Russian tax resident if its place of effective management is in Russia, or if it voluntarily applies for resident status through a Russian branch. Residents are taxed on worldwide income (13-22% progressive rates); non-residents face a flat 30% rate on Russian-source income only, with narrow exceptions such as Highly Qualified Specialists (13% from day one on labor income regardless of residency status).
A non-Russian entity has a Russian permanent establishment through a fixed place of business or a dependent agent habitually concluding contracts in Russia on the entity's behalf, following the OECD Model Treaty definition as applied under Russian domestic law and any applicable tax treaty.
A foreign entity (corporation, trust, foundation, or similar structure) is a Controlled Foreign Company where a Russian tax resident holds a 25% or greater interest, or 10% or greater if Russian residents collectively hold more than 50%. Controlling persons must generally include the CFC's undistributed profits in their own taxable income pro rata. Exemptions apply where the CFC is resident in a jurisdiction with an information-exchange treaty and either its effective tax rate is at least 75% of the Russian rate, or its passive income does not exceed 20% of total income. Individuals may alternatively elect a fixed lump-sum CFC tax (a flat annual amount regardless of actual profits) in lieu of profit-based reporting.
Under Article 269 of the Tax Code, debt owed to a foreign entity that directly or indirectly owns more than 20% of the Russian borrower (or debt guaranteed by such an entity) is "controlled debt." Where controlled debt exceeds a 3:1 debt-to-equity ratio (12.5:1 for banks and qualifying leasing companies with at least 90% leasing-derived income), interest on the excess is non-deductible and may be recharacterized as a dividend subject to withholding tax.
Russia does not use an elective check-the-box classification system; entity classification generally follows the entity's actual legal characteristics under Russian law. Russia does not have a comprehensive ATAD2-style anti-hybrid regime (Russia is not an EU member and is not bound by the EU directive), though Russia's own strict CFC regime (see CFC section above) substantially reduces the practical scope for classic hybrid-mismatch deferral planning involving Russian-controlled structures.
A Russian "currency resident" - which since 1 January 2018 includes all Russian citizens without exception, plus foreign nationals holding a Russian residency permit - must notify the Federal Tax Service at their place of tax registration within one month of opening, closing, or changing the details of any account (including deposit accounts) held at a bank or other financial-market organization located outside Russia. Since 1 January 2020, this reporting obligation was expanded beyond bank accounts to cover accounts held with foreign brokers, depositories, pension funds, and insurance companies. Russian residents must also file an annual report on the movement of funds through each foreign account, covering the full calendar year. Currency residents who spend more than 183 days per year abroad are exempt from these notification and annual-reporting obligations for accounts held in OECD/FATF member countries, provided the account's annual turnover or year-end balance does not exceed RUB 600,000 (approximately EUR 6,000). Penalties under Article 15.25 of the Russian Code of Administrative Offenses range from RUB 1,000-1,500 for individuals filing late or on the wrong form, up to RUB 4,000-5,000 for a complete failure to notify (with substantially higher penalties, RUB 50,000-1,000,000, for legal entities).
Russia provides a participation exemption for qualifying dividends received by a Russian company from a foreign subsidiary: a Russian parent holding at least 50% of the subsidiary's capital for a continuous minimum 365-day period can generally receive those dividends at a 0% Russian tax rate, subject to the subsidiary not being resident in a jurisdiction on Russia's own blacklist of low-tax states.
Russia has a real foreign tax credit regime available to both individuals and companies for foreign tax paid on foreign-source income also taxed in Russia, capped at the Russian tax otherwise due on that income - though Russia's CFC regime already taxes controlled foreign entities' profits on a current basis (see CFC section above), so the credit's practical role is narrower for CFC-attributed income specifically than for ordinary foreign-source income.
Russia has signed approximately 84 double tax treaties. Following Presidential Decree No. 585 (August 8, 2023) and Federal Law No. 598-FZ, Russia unilaterally suspended the reduced-withholding-rate provisions of 38 treaties with countries on its "unfriendly" list - including the US, UK, Germany, France, Japan, Canada, Australia, Singapore, Switzerland, and all EU member states - while leaving core provisions (residency definitions, double-tax relief mechanics, information exchange) formally intact. Separately, several treaties have been permanently denounced rather than merely suspended: the Netherlands (effective January 2022), Denmark (January 2024), Latvia (May 2022), and Lithuania (January 2026). The US formally suspended its side of the treaty in August 2024. Given the pace of change, always verify a specific treaty's current operational status before relying on it - the Ministry of Finance and Federal Tax Service publish current guidance.