Foreign companies touch the Russian tax system more often than they expect: a local subsidiary or branch, VAT on electronic services supplied to Russian customers, withholding tax on Russian-source income, or a permanent establishment created by people on the ground. Since 2023 the partial suspension of double tax treaties with a number of states has changed familiar answers — old structures need re-checking.

What we do

  • Permanent establishment analysis: whether your Russian activity creates a taxable presence and what follows;
  • VAT on e-services: registration, invoicing and filing for foreign providers of digital services to Russian customers;
  • Withholding tax on dividends, interest, royalties and other Russian-source income — including where treaty relief no longer applies after the suspension;
  • Tax registration and reporting of branches and representative offices;
  • Responses to tax authority requests, pre-audit analysis and representation in tax disputes;
  • Tax aspects of exit: liquidation, asset sales and profit distribution.

FAQ

Our treaty used to reduce withholding tax — does it still?
For many states, key treaty articles are suspended, and domestic rates apply unless a specific exception exists. We verify the current status for your jurisdiction and income type — do not rely on pre-2023 advice.

Can you handle filings, not just advice?
Yes, together with accredited accountants we prepare and file the returns and represent you before the tax authorities.

Roman Yankovsky
Roman Yankovsky Senior Partner, PhD in Law
Lecturer at the Higher School of Economics. Specializes in IT law, venture deals, artificial intelligence, and Big Data.

Our Experts

Роман Михайлович Янковский

Roman Yankovsky

Senior Partner, PhD in Law

Lecturer at the Higher School of Economics. Specializes in IT law, venture deals, artificial intelligence, and Big Data.

Ольга Владимировна Морозова

Olga Morozova

Senior Consultant

Expert in structuring international transactions and corporate governance. Has advised on deals worth more than $2 billion in aggregate.

Шаблон Мужчина 2

Anton Belov

Associate

Reviews corporate structures, constitutive documents, and related-party transactions.

360°
Comprehensive Approach
AI
AI Analytics
90%
Services provided remotely

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