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

The UK has confirmed its approach to the OECD’s side-by-side deal, but US-parented groups may find pillar two compliance remains far from straightforward
Fragmented pillar two taxation and increased use of AI by tax authorities have left clients fearful of heightened disputes exposure
Grant Thornton Advisors’ latest acquisition has produced the fifth-largest US advisory firm by revenue, but there’s still a clear gulf between it and the big four
Crowe joins Grant Thornton, WTS and Ryan in attracting PE investment, suggesting that dealmakers remain bullish on the tax advisory sector
HMRC expects advisers to meet ever-higher compliance criteria. After 24 consecutive qualified audit opinions, many will ask whether HMRC should hold itself to the same standards
The purchase of Marosa represents the second major tax tech consolidation this week, raising questions of a broader industry trend
Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments
Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test
The deals for TP Accurate and Intra Pricing Solutions will enhance Alphatax’s ability to support clients with the full TP lifecycle, the tax tech provider claimed
The DS Advocates partner discusses career reinvention, tax disputes and why advisory and litigation experience should complement one another
Gift this article