Russia’s Ministry of Finance has clarified that international holding companies are not required to include the profits of their controlled foreign companies (CFCs) in their corporate income tax base for tax periods ending before 1 January 2029.

This exemption applies if the company meets the conditions outlined in Article 251, Paragraph 1(58) of the Tax Code.

The clarification was issued in Guidance Letter No. 03-12-11/5/124819, published on 12 January 2025.

Earlier, the government of Russia announced new tax rules that will exempt profits of foreign collective investment structures from taxation on 31 August 2023.