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Changes in Russian tax residency rules

Russian Desk

Russian Desk

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Individuals residing in Austria and having significant business or personal ties to Russia could be affected by envisaged changes to Russian tax residency rules.

What is NEW?

It has been recently announced that Russian tax residency rules for individuals will be made more stringent. This means that the centre of vital interests will be determined if an individual is a tax resident of Russia. As a result, individuals with significant Russian ties may be qualified as Russian tax residents regardless of the number of days they actually spend in Russia.

What are the consequences?

Many Russian individuals maintain their status as non-residents in Russia.
If individuals are qualified as Russian tax residents, they will be required to disclose their foreign companies to the Russian tax authorities, pay Russian tax on the profits of their CFCs, disclose and tax certain types of foreign income in Russia. In addition their bank account information can be disclosed to Russian authorities (according to the currently applicable rules of automatic exchange of information).

How can we help?

  • KPMG Austria will gladly provide an initial analysis of tax consequences in connection with such change in Russian legislation.
  • Together with our Russian colleagues we will prepare proposals on how to minimize risks in connection with the change of residency.
  • KPMG Austria will assess the current asset-structure of the individual and will indicate risks regarding possible CFC aspects and automatic exchange of information rules.


Our Experts

Michael Petritz

Viktoria Kraus

Anton Kirnazhytski - ​​​​​​​Native Russian speaker 

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