Russian Tax Authorities tighten control over individuals considered “Special Residents” for currency control purposes
In recent practice, the Russian Federal Tax Service (RTA) is increasingly requesting additional documentation from Russian citizens residing abroad for more than 183 days per year — the so-called “special residents”.
“Special residents” are exempt from the obligation to submit an annual Cash Flow Report (CFR) for their foreign accounts.
Previously, a copy of a foreign passport with border control stamps was generally sufficient to confirm such status.
Now, however, tax inspectors are requiring a broader set of documents, citing the following concerns:
- a citizen may possess two valid foreign passports;
- border crossings may not be recorded, such as when traveling with a domestic passport or via automated border control systems.
Among the documents we’ve seen requested:
- employment contracts with foreign companies,
- lease agreements,
- hotel bills,
- boarding passes,
- phone bills showing roaming usage,
- and other personalized evidence of residence outside Russia.
If the RTA deems the evidence insufficient, the individual’s status may be revised to that of a currency resident, triggering the legal obligation to submit CFRs.
Failure to comply may result in an administrative fine of 2,000 to 3,000 RUB.
If you’ve received such a request from the tax authorities, we are ready to assist you in preparing the proper documentation and defending your position.
