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

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
The Office for Budget Responsibility’s pessimistic pillar two forecast accompanied the UK chancellor’s muted Spring Statement, dubbed ‘as dull as possible’ by one adviser
Digital tax reform is dissolving the old ‘temporal buffer’, forcing systems, institutions, and professionals to adapt as real-time reporting reshapes governance, capability, and compliance
Our first instalment features analysis of Deloitte’s landmark EMEA merger, Donald Trump’s Supreme Court tariff showdown and Venezuela’s tax evolution
While some believe it could have a positive effect on the wider advisory landscape, others argue that HMRC’s ‘red tape’ exercise won’t deter bad actors
The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos
The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week
Gift this article