Foreign entities must claim withheld corporate tax refunds within three years, filed with the tax authority of the withholding agent, unless a tax treaty sets another deadline.
The Russian Ministry of Finance (MoF) has clarified the timeframe for refunding corporate income tax previously withheld from payments made to foreign organisations. The official position was outlined on 12 March 2026 in Letter No. 03-08-13/6622.
According to the letter, a foreign recipient of income, or their representative, must submit an application for a tax refund along with supporting documents within three years from the end of the tax period in which the income was paid. In line with Article 285 of the Russian Tax Code, the tax period for corporate income tax is defined as a calendar year.
Refund applications and documents must be filed with the tax authority at the place of registration of the tax agent that withheld the tax. The legal basis for this procedure is established by paragraphs 2 and 3 of Article 312 of the Tax Code of the Russian Federation.
The letter also notes that different deadlines may apply if specified under a mutual agreement procedure conducted according to an international tax treaty to which Russia is a party.
This guidance ensures foreign organisations are aware of the procedural requirements and deadlines for claiming refunds of corporate income tax withheld in Russia.
