Russia: Russia’s participation exemption: A clarification

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Russia: Russia’s participation exemption: A clarification

Sponsored by

sponsored-firms-kpmg.png
li-russia-as246121715.jpg

A brief update to Nuances embedded in Russia’s participation exemption (ITR, January 29 2019) by Viktoria Ivashchenko, Denis Gamiy and Dmitry Garaev of KPMG.

On January 29 2019, we published the article 'Nuances embedded in Russia's participation exemption' in which we analysed certain nuances embedded in Russia's participation exemption rules. Since then there have been further developments in the law, one of which is worth noting.

It used to be that one criterion for applying the participation exemption was that an applicant should have acquired shares or participation interest before January 1 2011. The law did not define what is understood by the term 'acquired', creating ambiguity as to how this term should have been interpreted. This is no longer an issue, as the criterion "acquired after January 1 2011" has been abolished. This condition is still relevant for shares or/and participation interest sold by an applicant before January 1 2019, but should not cause disputes for those sold after that date.

KPMG
W: www.kpmg.ru

more across site & shared bottom lb ros

More from across our site

Despite the increased yield, the time taken to resolve enquiries was at a six-year high, new HMRC statistics have revealed
The High Court’s dismissal of barrister Setu Kamal’s legal challenge represents the first successful strike-out under a new law on SLAPPs
IP lawyers, who say they are encouraging clients to build up ‘tariff resilience’, should treat the risks posed by recent orders as a core consideration in cross-border licensing
As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency
However, women in tax face greater career obstacles than their male counterparts, an exclusive ITR survey of more than 100 women tax leaders revealed
Under Jeff Soar’s leadership, WTS UK aims to scale to 100 partners within five years and challenge the big four
As the firm embarks on a major shakeup of its EMEA partnerships, some staff will be watching nervously
The buyout of Hucke and Associates continues Ryan’s streak of firm acquisitions; in other news, a UK appeal against VAT on private school fees was dismissed
Tax teams are responding to usual client demand in the region, albeit with increased working from home flexibility, local sources indicate
A 120-plus-day delay to refunds would cost taxpayers almost $3bn in additional interest, the Cato Institute warned; plus indirect tax updates from February
Gift this article