Russia: Russia’s participation exemption: A clarification

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

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 & bottom lb ros

More from across our site

The OECD has vowed to continue working with the US despite the president effectively pulling the country out of the organisation’s global minimum tax deal
Norton Rose Fulbright highlights a Brazilian investment fund as a practical example of how new Dutch tax rules will require significant attention from foreign companies
Thomson Reuters now has ‘end-to-end capability’ for its tax workflow business, according to its president for tax accounting and audit professionals
Patrick O’Gara, who is rated as a ‘highly regarded practitioner’ by World Tax, had spent over 20 years at Baker McKenzie
If approved, it would become the first ‘big four’ firm to practise law in the US; in other news, Morrison Foerster hired a new global tax co-chair
The ‘birth date’ of the service, which will collect tariffs, duties and other foreign revenue, will be January 20
Awards
Submit your nominations to this year's WIBL Americas Awards by February 28
Awards
Research for the annual Women in Business Law Awards has begun – submit your entries by February 28
In-house counsel across a number of regions are unimpressed with their tax advisers’ CSR efforts, according to ITR+ research
Firms are starkly divided on the benefits of specialist tax litigation teams over generalist practices, ITR’s analysis also finds
Gift this article