Kaliningrad Region Development Corporation sar39@kgd-rdc.ru +7 (4012) 303-110
TAX INCENTIVES FOR INTERNATIONAL SAR PARTICIPATING COMPANIES
TAX BENEFITS FOR SPECIAL ADMINISTRATIVE REGION PARTICIPANTS
Currency regulation
International companies-SAR members
Other legal entities registered in the Russian Federation
Currency «residence»
Non-resident
Resident
Currency control
Lack of currency control + The right to transfer without limitation of foreign currency of the Russian Federation from one's bank accounts (from bank deposits) with banks outside the territory of the Russian Federation to one's bank account (to bank deposits) at authorized banks, as well as the right to transfer without limitation foreign currency and the currency of the Russian Federation from its bank accounts (from bank deposits) in authorized banks to its accounts (in deposits) at banks outside the territory of the Russian Federation
Availability of currency control
Taxation of the IHC and its affiliates
Tax rate on SAR territory
Tax rate on the rest of the Russian Federation
Dividends of the IHC, received from Russian and foreign subsidiaries
0% (with a share in the capital more than 15%)
0% (given the share in the capital is more than 50%) 13% (given the share in the capital is less than 50%)
Dividends of foreign companies, received from INC (for PJSC)
5%
15% (can be reduced to 5% if there is a Double Taxation Avoidance Agreement)
Incomes from selling of stocks (shares) of Russian and foreign companies
0% (with a share in the capital more than 15% and a tenure of more than 1 year)
0% (with a tenure of more than 5 years) 20% (in other cases)
Incomes of the Russian shareholders of the IHC in room of the profit of the IHC (the profit of the controlled IHC is not taxed
Tax free
Taxed at a rate of 20%
IHC incomes in the from of profits of foreign companies controlled by IT
Tax free
Taxed at a rate of 20%
BENEFITS IN THE FIELD OF SEA AND AIRCRAFT OPERATION FROM 01.01.2020
TAX CODE OF THE RF
CONTENT OF BENEFITS
Subparagraph 12, article 150, chapter 21
The import of ships subject to registration in the Russian Open Register of Ships by persons - SAR participants to the territory of the Russian Federation and other territories under its jurisdiction is not subject to taxation (exempt from tax) on value added tax
Paragraph 1, article 251, chapter 25
The following are not taken into account when determining the tax base for corporate profit tax: income of shipowners received from the operation and (or) sale of ships registered in the Russian Open Register of Ships by persons - SAR participants; income of shipowners received from the operation and (or) sale of ships built by Russian shipbuilding organizations after 01.01.2010 and registered in the Russian Open Register of Ships by persons - SAR participants.
Paragraph 2, article 358, chapter 28
Ships registered in the Russian Open Register of Ships by persons - SAR participants and aircrafts registered in the State Register of Civil Aircraft by persons - SAR participants are not subject to taxation on transport tax
Paragraph 4, article 374, chapter 30
Ships registered in the Russian Open Register of Ships by persons - SAR participants and aircrafts registered in the State Register of Civil Aircraft by persons - SAR participants are not recognized as objects of taxation on property tax of organizations
Paragraph 1, paragraph 2, article 427, chapter 34
For payers - SAR participants making payments and other remuneration to crew members of ships registered in the Open Register of Ships for the performance of labor duties of a crew member — the insurance premium rates for compulsory pension insurance, for compulsory social insurance, for temporary work incapacity and in connection with motherhood, for compulsory medical insurance - are set at 0% for the period up to 2027 inclusive