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. 

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