Category: News

Juralink’s customs lawyers have recently registered the increase of queries relating to the disputes with Russian customs on non-declaration of goods.

Indeed, individuals when crossing the Russian border, although not pursuing commercial interests, often are not concerned about the rules for declaring the accompanying items, assuming that goods intended for personal use purchased by themselves or received as a gift are not subject to customs control and duties.

However, this is not always the case.

First comes the stress experienced by the person, who undergoes the customs scrutiny and is often confronted with immediate confiscation of their favorite jewelry or watches for a customs expertise. Hereafter, receipt of official notice on administrative investigation and impending penalties or even criminal liability. All this can be avoided if you inform yourself on declaration requirements when entering Russia beforehand.

Below you can find a simplified categorization of goods when imported into Russia:

If you import a precious watch for further sale in Russia a customs duty of 7 to 12% is charged upon import, depending on the product type, and VAT.

Personal jewelry newly bought when enjoying a shopping day during the holiday can be imported duty-free up to the value of 10.000 euro if traveling by plane, where a customs duty of 30% of purchase price would become applicable above the specified threshold.

Used personal belongings are generally imported duty-free.

It is the customs officer in place to decide whether he/she acknowledge the imported goods as commercial or personal. In doing so the officer would take into account:

1. the person’s declaration;
2. the nature and quantity of goods;
3. the frequency of a person crossing the border and (or) the movement of goods across the customs border by this person or to him.

If your personal belongings are subject to duty, they must be declared upon import and you should cross the customs border using the red channel at all times. Please, make sure you also have the documents confirming the value of the imported goods (receipt, payment checks, etc.) with you. In the absence of the evidencing documents, the customs authority determines the value of the imported items on their own.

The export of personal goods from Russia is not subject to any duties or taxes. However, in some cases it is still worth looking into the “red corridor” and filing a declaration to make sure you won’t face any problems when coming back with the same things.

Be aware that failure to declare your jewelry when exceeding the duty-free limit is punishable by an administrative fine ranging from 50% to 200% of the value of the imported and not-declared items and may also lead to the confiscation of such personal goods. At the same time non-declaring of goods (jewelry, watches, jewels) in case their value exceeds 1,000,000 RUR (approx. 10,000 EUR) may also result in criminal liability for smugglers punishable by a fine in the amount of up to 1,000,000 RUR or in the amount of the wages or other income of the convicted person for a period of one to three years, or by forced labor for up to five years, or by imprisonment for the same term.

Taking into consideration the above legal consequences, we recommend to promptly seek for a competent legal advise and a customs lawyer to represent your interests in the event you were stopped at the green channel and are now being confronted with a customs investigation for non-declaring of accompanying goods. Professional support is valuable not only to decrease the tension in the negotiations with the authority, but also to secure you from swindlers trying to use the situation, as well as brings practical positive results such as reduction of the customs penalties up to overall dismissal of the customs investigation and receiving back your valuable belongings.

Juralink customs experts would be glad to provide you with any further advise regarding dealings with Russian customs authorities. Do not hesitate to contact us via our contact form or on the phone.

Foreign citizens have recently got more options for acquiring Russian citizenship and residence permits in accordance with several legal acts introduced in August 2024:

• Federal Law No. 253-FZ dd. August 8, 2024 “On Amendments to Certain Legislative Acts of the Russian Federation” (hereinafter the “ FL No. 253”),

• President Decree No. 702 dd. August 19, 2024 “On Providing humanitarian support to persons sharing traditional spiritual and moral values of Russian” (hereinafter “Decree No. 702”).

Russian compatriots living abroad

First option is applicable for “compatriots living abroad”, who can now obtain a permanent residence permit in a simplified way, bypassing the need to obtain a temporary residence permit. To make use of this option a potential repatriate shall officially participate in the “State Program on assistance to the voluntary resettlement to the Russian Federation of compatriots living abroad”, or obtain the status of a family member of a participant of the said State Program.

An application for a Russian residence permit can be submitted abroad to the diplomatic mission or consular office of the Russian Federation in the country, where the application for participation in the State Program was earlier submitted to. Residence permit is issued only upon the foreign citizen undergoes the mandatory state fingerprint registration and photographing, as well as submits results of a medical examination. The changes will take effect on November 6, 2024.

Note, following foreign citizens can be acknowledged as compatriots living abroad:

Persons and their descendants residing outside the territory of the Russian Federation and belonging, as a rule, to the peoples historically residing in the territory of the Russian Federation, as well as persons who have made a free choice in favor of spiritual, cultural and legal ties with the Russian Federation, whose relatives in the direct ascending line previously resided in the territory of the Russian Federation, including:

• persons who were citizens of the USSR, residing in states that were part of the USSR, who received citizenship of these states or became stateless persons;
• people (emigrants) from the Russian state, the Russian Republic, the RSFSR, the USSR and the Russian Federation who had the appropriate citizenship and became citizens of a foreign state or stateless persons.

Foreigners who share traditional Russian values

A second simplified option newly implemented by the Decree No. 702 introduced a separate ground for acquisition of a temporary Russian residence permit for those foreign citizens, who share “traditional Russian spiritual and moral values and oppose the destructive neoliberal ideological agenda” in their home country.  Such persons can now apply for a temporary residence permit without an established foreigners quota, proof of Russian language proficiency or knowledge of Russian history and the country’s laws.

The list of traditional Russian spiritual and moral values provided for by the President Decree No. 809 dd. November 9, 2022 includes: life, dignity, human rights and freedoms, patriotism, civic consciousness, service to the Fatherland and responsibility for its fate, high moral ideals, strong family, the priority of the spiritual over the material, humanism, mercy, justice, collectivism, mutual assistance and mutual respect, historical memory and the intergenerational continuity, the unity of the peoples of Russia.

To arrive in the country, foreign citizens will be able to obtain single-entry ordinary private visas for 3 months.

The Decree No. 702 comes into force on September 1, 2024. Still the list of foreign states implementing policies that impose destructive neoliberal ideological attitudes that contradict traditional Russian spiritual and moral values is yet to be approved by the Russian Government as per the recommendation of the Ministry of Foreign Affairs. Hereto until the implementation of the detailed regulatory base and official explanations the obtainment process of such simplified temporary residence permit will not become workable.

Personal interview

Contrary to the above some immigration restrictions also become due upon the Government Decree No. 1087 tightening the conditions of entry into the Russian Federation, which appeared on August 15, 2024. In accordance with the updated regulation, visa applicants will have to undergo a personal interview to verify the purpose of the trip and the conditions of stay in the Russian Federation.

Whenever you are seeking support regarding immigration opportunities to Russia, our professional lawyers will be glad to guide you through this sophisticated process, explain and settle all kinds of documentation for obtainment of residence permits, business visas, student visas, Russian citizenship or even opening your own business or start-up in Russia.

Russia is planning several changes into its tax legislation, whose effects will swiftly become noticeable among the taxpayers. Hereto it is planned to raise several tax rates to fill in the gaps in the state budget. The new tax rules are expected to come into effect already on January 1, 2025.

The withholding tax will be raised from 20% to 25% (except for the special tax rates such as dividends or intercompany services). Therefore, companies based in EU and USA (or other western countries with whom the Double Taxations Treaties were recently suspended) and using for example licensing structures, will face a royalty withholding tax of 25%.

The general corporate tax rate should also be increased to 25%

IT companies’ tax is expected to become 5% in 2025-2027 whereafter it could switch to the general corporate rate.

The tax hike is supposed to be balanced by additional tax incentives like:

• Improvements to the investment income tax deduction and making it permanent;
• Introduction of a new federal investment income tax deduction (FINV);
• Increase of the depreciation rate applicable to high-tech equipment, R&D expenses, as well as software registration expenses from 1.5 to 2;
• Extension of the regime of regional investment projects for entities subject to inclusion into the register.

The personal income tax rate will be restructured using an extended progression:

• Earnings up to 2,4 million RUR – 13%,
• Earnings above 2,4 up to 5 million RUR – 15%,
• Earnings above 5 up to 20 million RUR – 18%,
• Earnings above 20 up to 50 million RUR – 20%,
• Earnings above 50 million RUR – 22%.

Still some individual earnings will be exempt from the above 5-scale PIT rate. Current two tax rates system of 13% for earnings up to 2,4 million RUR and 15 % for earnings above should be applicable to the:

• Dividends,
• Interest from deposits in Russian banks,
• Sale of real property,
• Security transactions,
• Sale of shares in Russian LLC’s in case they were owned for longer than 5 years.

However, if the total tax base during one year exceeds 50 million RUR, then the taxpayer should lose the right to use:

• Exemptions for the period of ownership upon sale shares/shares owned more than 5 years;
• Deduction in the form of financial results for operations on IIS (individual investment account);
• Deduction in the form of a positive financial results from marketable securities, owned for more than 3 years;
• Exemption in relation to payments under long-term savings agreements.

For individuals not being tax residents of Russia but working remotely for Russian companies the same tax rates as for the tax residents should apply.

The current tax exemption for long-term ownership of shares in Russian entities should become available only for Russian tax residents.

Property tax for individuals, being a local tax, could be raised from maximum of 2% to 2,5% by the municipalities for expensive real property which cadastral value exceeds 300 million RUR.

Mineral tax for coal, iron ore, diamonds, potassium salts will be raised as well.

Excise duties will become applicable for wider range of goods, such as

• An alcohol-containing substance of ethyl alcohol,
• Unlisted alcohol-containing medications,
• Pharmaceutical substance of ethyl alcohol,
• Nicotine raw materials,
• Tobacco-free nicotine mixture for heating.

In accordance with the recently introduced amendments to the Government Decree No. 295 dd. March 6, 2022, establishing the rules for issuance of the Government Commission Approvals aimed at control of foreign investments in the Russian Federation and implementation of additional temporary economic measures to ensure the financial stability of the Russian Federation, the list of requirements to transactions conducted in regard to securities and shares of authorized capitals of Russian companies has been updated.

The amendments re-confirmed the requirements that had earlier been specified in the Minutes of the Subcommittee of the Government Commission for the control of foreign investments in the Russian Federation No. 171/5 dd. July 7, 2023, whereas the latter made important clarifications to the procedure of application for a Government Commission Approval, inter alia for intra-group transactions and transactions between persons from “unfriendly” states.

The actual general requirements for a transaction conducted in regard to securities and shares of authorized capitals of Russian companies and involving foreign persons from “unfriendly states” are as follows:

1. provision of a report on independent appraisal of the market value (hereinafter “Report”) supplemented by an expert opinion thereon, whereas both are arranged by a qualified appraiser included in the list of the appraisers recommended by the Government Commission;
2. sale of assets with a discount of at least 50% of the market value of the relevant assets specified in the Report;
3. payment of the exit tax 15 % (amount updated by the Minutes of the Meeting of the Subcommittee of the Government Commission for the control of foreign investment in the Russian Federation dd. September 26, 2023 No. 193/4);
4. in case of acquisition of shares constituting the authorized capital of a public joint stock company (hereinafter “PJSC”), placement of up to 20% of the acquired of shares at an organized auction (placement not later than 1 year from the date of the transaction, with the placement lasting for not more than 3 years; in case of reorganization in the form of a company joining a PJSC, placement of shares of the PJSC at an organized auction in the amount equivalent up to 20% of the shares of the company joined);
5. in case of termination of the public status of a joint stock company (hereinafter “JSC”) or its liquidation as a result of implementation of a transaction, placement of up to 20% of shares of a PJSC (newly created or as a result of a JSC becoming PJSC) at an organized auction;
6. establishment of key performance indicators and their target values in regard to the party purchasing the securities\shares;
7. repurchase of an asset at market value on the date of realization of an option concluded, presence of economic benefits for the owner of the asset (being a resident) and limitation of the validity period of the Government Commission Approval (as a general rule – 2 years);
8. use of the type “C” account in terms of the transfer of funds to the party being a person from an “unfriendly” state, or conduct of transactions in rubles with the use of the banking system of the Russian Federation without transferring funds outside the Russian Federation, or availability of installment payments in case of transactions being conducted to the bank account located outside the Russian Federation;
9. availability of other permits if so provided for by the legislation of the Russian Federation.

NOTE: provision of the documents as per the pp. 1 and 6 is not required for intra-group transactions and transactions conducted between foreign “unfriendly” persons, making such transactions also not subject to the 50% discount from the asset value and 15% exit tax Commission requirements.

Major changes have been recently introduced to regulations concerning highly qualified specialists (hereinafter referred to as the “HQS”) in accordance with the recently adopted Federal Law No. 316-FZ, which made amendments to the Federal Law No. 115-FZ dd. July 25, 2002 “on the legal status of foreign citizens in the Russian Federation”. A number of changes have already come into force, but the most part will be implemented early in 2024.

Effective from July 10, 2023:

1. in case of prolongation of a working permit (hereinafter referred to as the “WP”) of an HQS, the latter as well as members of their family are to undergo medical examination within the 30-days term after the decision on the WP prolongation is made or from the day they enter the territory of the Russian Federation.
2. requirement to undergo medical examination on a repeated basis (upon expiration of a 1-year term from the day the person had undergone such examination) is no longer applicable to HQS family members.

Effective from January 06, 2024:

1. an HQS who has been carrying out activities on the territory of the Russian Federation for 2 years, is now entitled to receive a permanent (unlimited) residence permit as well as their family members. The only condition in addition to the 2-years term is the employer of the HQS having accurately paid all taxes and fees for the entire period of stay of the HQS on the territory of the Russian Federation.
2. the period of stay of an HQS on the territory of the Russian Federation in case of termination of their employment contract has been reduced to 30 days, during which the HQS is to find a new employer and arrange the necessary documentation. If the foreigner fails to meet the aforementioned requirements and deadlines, they and their family are to leave the Russian Federation within 30 calendar days.
3. new term for receipt of WPs has been established (applicable to both new and prolonged WPs) – 30 days from the date the decision on issuance of such WP made. If the WP is not received by the HQS within the specified period of time, such WP gets revoked, then the HQS and their family have to leave the territory of the Russian Federation within 15 calendar days after decision thereon is made. Upon a respective application the 30-days term can be prolonged, but not more than for 30 days from the date of receipt of such application by the Ministry of Internal Affairs.
4. employers are no longer able to hire HQS within the 2-years term, in case the former failed to file (during the last reporting period) accurate information on the amount of personal income tax concerning HQS to the tax inspectorate.

Will come into force from March 01, 2024:

The lowest salary/remuneration threshold for HQS has been raised to 750 thousand rub per quarter. In accordance with the clarifications provided by the Ministry of labor and social security of the Russian Federation, salary in the amount specified should already be paid for the period January-March 2024, respective data should be included in the notification filed to the Ministry of Internal Affairs for the 1st quarter of 2024.

The procedure of obtainment of residence permits has been much simplified for foreign investors. From now on, a foreigner applying for such residence permit and satisfying the criteria introduced by the Russian Government can undergo the procedure in an expedited manner, provide a significantly shortened set of documents. The governmental body the applications should be addressed to is the Ministry of Economic Development of Russia.

As established by the Government Decree No. 2573 dd. December 31, 2022, a foreign investor willing to apply for a residence permit is to satisfy one of the following criteria:

• investment of 15 million RUR or more in important social projects implemented in the Russian regions,
• investment of 30 million RUR or more in Russian companies,
• foundation of an active legal entity with at least 4 million rubles in taxes and fees paid annually (legal entity to be founded two or more years prior to application),
• purchase of real estate in Russia with minimal cost depending on the region of the country (Moscow: 50 million RUR, Far Eastern Federal District: 20 million RUR, other regions in Russia: 25 million RUR)

The set of documents to be provided as proof of satisfaction of one of the abovementioned criteria, as well as other important requirements, are approved by the Government Decree No. 1375dd. August 23, 2023. The results of the evaluation of the submitted application should be expected within 30 working days.

We would like to draw your attention to the return of limitation terms for validity of work permits for highly qualified specialists (hereinafter referred to as the ‘HQS’). In case a HQS stays outside Russia longer than 6-months (continuously) his working permit can be revoked.

For most countries, the 6-months period will be monitored and recorded from October 13, 2022 (except for the Republic of Abkhazia, Armenia, Belarus, Kazakhstan, South Ossetia, Donetsk People’s Republic, Luhansk People’s Republic, People’s Republic of China, Mongolia, Ukraine, Kyrgyz Republic – for those the start date is August 18, 2022).

Accordingly, on April 12, 2023, the first period of the 6-month term will end.

In case a HQS has been staying outside Russia since October 13, 2022 until April 12, 2023 the authorities can make a decision to revoke the HQS’s work permit.

Russia prepares to strike back in response to the 10th sanction package and its blacklisting as a tax haven i.e. non-cooperating jurisdictions in tax matters by the EU. 

Previous week the Russian Ministry of Finance together with the Foreign Ministry issued a joint press release proposing the Russian President to suspend DTTs with all countries that have introduced unilateral economic restrictions against Russia.

In case the envisaged Presidential Decree will come true the DTTs provisions will presumably cease to apply from the moment of it’s publication, as it happened in the case of Latvia.

Involved jurisdictions

Supposedly all countries specified as “unfriendly” (39 states at the moment) will be tangled by the new regulation. Besides EU it would be Australia, Albania, Canada, Iceland, Japan, Montenegro, New Zeeland, Norway, Singapore, South Korea, Switzerland, UK and US. 

Tax consequences  

DTTs suspension will have following major consequences:

1. Upturn of tax burden for passive income payments in favor of residents of unfriendly countries:

• Royalty and interest income 20%
• Dividend income 15%
• International transport service 10%

2. Difficulties with getting a foreign ta credit

• no foreign tax credit would be granted to the natural persons and legal entities in regard to the dividend income, 
• getting a foreign tax credit for further passive income would require extended documentation obligations;

3. Implications for of CFCs (controlled foreign companies) located in unfriendly countries:

• Profits cannot be exempted from taxation on the basis of a high effective rate;
• Mandatory provision of auditor report on CFC’s financial results; 

4. Increased risks of double taxations (for example in double residency conflicts) 

5. Multilateral pricing agreements with the participation of unfriendly countries, as well as to conduct of mutual agreement procedures could be no longer used;

6. Difficulties with the information exchange between the countries.

Taking into account that decision to suspend the DTT will affect the interests of EU players remaining on the Russian market and significantly increase the tax burden on investments in Russia we will closely monitor the implementation of the described proposal and will be glad to jointly assess the possibilities and potential restructuring needs on the side of business.

Please feel free to contact us.

Rights restrictions of “unfriendly“ shareholders participating in big russian market players

The recently released Decree of the President of the Russian Federation dd. January, 17 2023 establishes temporary procedures of corporate decision-making for Russian legal entities (i.e. the meetings of shareholders, boards of directors or other collegial executive bodies).

The new procedure is applicable to the entities meeting the following requirements simultaneously:

• The entity belongs to energy\machinery engineering\trade industries,
• Its revenue in the year prior to the intended decision’s adoption is more than 100 billion rubles (approx. 1 319 600 00 EUR),
• Sanctions against the beneficiary owner\controlling person of the entity were imposed by ‘unfriendly’ states[1] or unions,
• Not more than 50% of the share capital belongs to the shareholders from the ‘unfriendly’ states.

As from January, 17 2023, it is allowed for such entities to make decisions on the agenda without taking into account the votes belonging to persons from ‘unfriendly’ states (except for those who have their registration in Russia) and/or candidates nominated by such persons to the governing bodies. The votes of the mentioned persons and candidates also should not be taken into account when determining the quorum.

However, the new temporary procedure does not come into force automatically, it can only be adopted by a majority vote of the company’s shareholders being from ‘not-unfriendly states’)

The Decree specifies what persons\entities are not to be considered as ‘unfriendly’:

• Citizens of the Russian Federation and persons\entities controlled by them,
• Persons coming from ‘not-unfriendly’ states exercising control over persons\entities from ‘unfriendly’ states on condition that such control was established before March, 01 2022,
• Persons, being under control of persons\entities from ‘not-unfriendly’ states (or under control of ‘not-unfriendly’ states themselves) on condition that such control was established before March, 01 2022.

---

[1] USA, Canada, Austria, Bahamas, Belgium, Bulgaria, Croatia, Cyprus, the Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Estonia, the Great Britain (including Jersey, Anguilla, British Virgin Islands, Gibraltar), Ukraine, Montenegro, Switzerland, Albania, Andorra, Iceland, Liechtenstein, Monaco, Norway, San Marino, North Macedonia, Japan, South Korea, Australia, Micronesia, New Zealand, Singapore, Taiwan, Isle of Man, Guernsey Island, the Bermuda, the British Antarctic Territory, the British Indian Ocean Territory, the Cayman Islands, the Falkland Islands, Montserrat, the Pitcairn Islands, Saint Helena, the Ascension and Tristan da Cunha Islands, the South Georgia and South Sandwich Islands, Akrotiri and Dhekelia, Turks and Caicos.

Barriers for foreign investors on the way out of the Russian market –

Mandatory Government Approval for transactions with Russian shares

On September this year Presidential Decree No. 618 introduced restrictions for foreign investors trying to sell their Russian businesses in order to slow down the outflow of investments from Russia. Since the issuance of the Decree it is required to obtain a mandatory approval of the Government Commission for transactions with shares of Russian limited liability companies (hereinafter LLC) where at least one of the parties involved is registered in or controlled from an “unfriendly” country[1].

You can find more about the Decree No. 618 in our previous article https://www.juralink.nl/en/new-obstacles-for-foreign-exit-strategies-from-the-russian-market/  

The Decree affects transactions that result in direct or indirect establishment, modification or termination of:

1. rights to own, use or dispose of shares in an LLC
2. other rights that allow determining the conditions for the management of LLCs or their entrepreneurial activities.

Subject of the approval[2]:

• Transfer of LLC shares to one (several) member(s) of this company or to a third party;
• Acquisition by an LLC of a share in its own authorized capital;
• Exit of the shareholder from an LLC by way of alienation of his share to the LLC or demanding such acquisition by the LLC;
• Transfer of LLC shares to an investment fund;
• Management contract on the transfer of powers of the sole executive body of a LLC;
• Corporate (Shareholder) agreement;
• Convertible loan agreement;
• Share pledge agreement;
• Pledge management agreement;
• Voluntary reorganization of an LLC;
• Joint Venture Agreements, concluded by an LLC;
• Trust or fiduciary agreement, or any other agreement, the subject of which is the exercise of rights on shares of an LLC;
• Other transactions (operations) entailing directly and (or) indirectly establishing, changing or terminating the rights of possession, use and (or) disposal of shares in the authorized capitals of an LLC or other rights that allow to determine the management conditions of an LLC and (or) conditions their business activities

Hereto the list of transactions is open for broad interpretation and can for example include option agreements, any introduction of changes into the LLC’s authorized capital (capital increase or decrease) or even amendments into the LLC’s Articles of Association, if such addresses the management /approval rights of shareholders.

The Application procedure is stipulated by the Governmental Decree dd. 6.03.2022 N 295

Applicant: both residents and non-residents from unfriendly states (any party)

Approval term: is not stipulated. There is no clear rule so far when and how often the commission meets. According to an official publication at one meeting of the Government commission, no more than 10 applications can be considered[3]. Based on our experience the application approval takes considerable time (at least 1 to 3 months).

Required documents and data:

1. Application in the form prescribed by the Ministry of Finance;
2. Petition in a free from, containing information about the planned transaction (purpose, subject, content, all essential terms of the transaction (including the price and payment terms), the planned duration of the consent, the number of votes for the shares that are the subject of the transaction);
3. Documents confirming the state registration of the applicant;
4. Constituent documents of the applicant;
5. Applicant ID, if it is an individual;
6. Information about the beneficiaries, beneficiaries and controlling persons of a non-resident associated with unfriendly countries;
7. Independent appraisal report on the market value of alienated shares (in some cases the Government commission advises on 50% discount to the established market value)
8. Information about the Russian and foreign accounts of the applicant and amount of funds on them;
9. Information about the order of transfer and use of funds received from the implementation of the transaction;
10. Shares and votes distribution after the transaction;
11. Rational for approval grant and consequences of refusal to grant permission for the applicant as well as for the socio-economic development of the Russian Federation

Nota bene: The Presidential Decree No. 618 does not affect transactions involving credit institutions and non-credit financial institutions, which are regulated separately.

Furthermore, the obtainment of Government approval in accordance with the Presidential Decree No. 618 does not eliminate the obligation for antitrust clearance, in case an envisaged SPA-transaction is also subject to FAS approval in line with general rules of Competition law.

In the event a strategic clearance is required, the rules of the Strategic Law No. 57-FZ dd. 29.04.2008[4] have primacy over the Government Commission approval.

If you are evaluating an exit strategy from the Russian market our M&A experts would be glad to assist you with the transaction structuring and implementation, accompany the procedure for obtaining permission from the Government Commission and complete all necessary registration actions.

---

[1] The list of unfriendly countries is determined in the Government Decree dd. 5.03.2022 N 430-r

[2] Official explanations No. 1 of the Ministry of Finance as of 13.10.2022 No 05-06-14PM/99138

[3] Clause 2.2 Extracts from the Minutes of the meeting of the subcommittee of the Government Commission for the Control of Foreign Investments in the Russian Federation dd. 14.03.2022 No. 9, released by the Ministry of Finance on 17.03.2022 No. 05-06-10 / BH-12520

[4] On the procedure for making foreign investments in business entities of strategic importance for ensuring the defense of the country and the security of the state