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.
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