Income obtained from transferring property and proprietary and non-property rights to companies, with the goal of increasing their net assets, is exempt from corporate income tax, as per recent amendments to the Russian Tax Code.
Among other things, income from dividends not claimed by shareholders and recovered as income by the company will also be exempt from taxation.
Therefore, in addition to there already being an exemption from taxes on the transfer of funds from shareholders (participants) with more than 50% of the capital in a company to a subsidiary, there will be additional opportunities for shareholders and participants, including minority ones, to invest tax-free in a company.
The amendments apply retroactively to relationships that began as of 1 January 2007. Consequently, property and proprietary and non-property rights transferred with the goal of increasing net assets may be exempt from corporate income tax.
[Federal Law No. 409-FZ, “On Amending Separate Legislative Acts of the Russian Federation, Specifically on Regulating the Payment of Dividends (Distribution of Profits)”, dated 28 December 2010]