Income from the sale of shares is not considered when calculating the tax benefit for private foundations.
The Russian Ministry of Finance has clarified that, when determining whether 90% of a private foundation’s income qualifies for the reduced corporate income tax rate (15%), only income types listed in the special official List may be taken into account.
Income from the sale of shares a in Russian companies is not included in this List and therefore cannot be counted toward the 90% threshold.
Letter of the Ministry of Finance of Russia dated March 20, 2025 No. 03-03-07/27539
This position should be carefully considered when planning the income structure of a private foundation for tax purposes.