01
Citizenship and tax residence are different concepts
Residence is normally based on physical presence and is tested under domestic and treaty rules.
- Days
- Baseline test: at least 183 days in 12 consecutive months
- Tax year
- Final PIT status is determined under annual rules
- Treaty tie-breaker
- Permanent home, centre of vital interests and other tests
- Evidence
- Travel, housing, family, work, business and certificates
- Non-resident
- Rate depends on income type and exceptions
02
The progressive scale applies by tranche
A higher rate generally applies to the relevant part of the main aggregate base, not automatically to all income.
- Up to RUB 2.4m
- 13%
- RUB 2.4–5m
- 15% on the relevant tranche
- RUB 5–20m
- 18% on the relevant tranche
- RUB 20–50m
- 20% on the relevant tranche
- Above RUB 50m
- 22% on the relevant tranche
03
Each investment and property return needs classification
Salary, dividends, interest, shares, securities and real estate can produce different bases, deductions and filings.
- Dividends
- Separate base and special scale
- Securities
- Acquisition cost, broker records and loss rules
- Real estate
- Holding period, documented cost and deductions
- Foreign income
- Treaty, foreign tax credit and evidence
- Benefits
- Standard, social, property and investment deductions
04
Foreign structures create disclosure as well as tax
Accounts, CFCs, foreign entities and distributions must be analysed together with residence and treaty treatment.
- Foreign accounts
- Opening and transaction notices where applicable
- CFC
- Control test, notices, profit and exemptions
- Trust/foundation
- Rights, control, distributions and reporting
- CRS
- Data exchange may reveal inconsistent positions
- Calendar
- Separate dates for returns, notices and payment