Capital Desk

Memo #1. When the tax clock moves

DRAFT · unpublished · 01.10.2026

Review date: 15 Nov 2026

The question. Russia's Ministry of Finance proposed on 24 Sept 2026 to tax passive income — property sales, dividends, securities, deposit interest — on the full 13–22% progressive scale instead of today's 13–15%, and to make mutual funds pay 15% on passive income (dividends, interest, rent, royalties) as it arrives rather than when investors are paid out [S1, S1b — document]. Reportedly only closed-end and interval funds for qualified investors would be affected [S2 — partial]. It is a draft, not law. For families with Russian assets — including those now in Dubai, Cyprus or Serbia — does it change when and how to sell, and how to hold?

Worked example (illustrative). Taxable gain on a sale: 100m RUB ≈ $1.19m at 84.34 RUB/$ (26 Sept 2026); no deductions, no other income that year; draft passed as is and effective 1 Jan 2027 (scenario).

OptionWhen the money arrivesTaxvs. A
AAll in 2026≈ $177k (14.95m RUB)—
BAll in 2027≈ $242k (20.40m RUB)+36%
CHalf in Dec 2026, half in 2027≈ $200k (16.85m RUB)+13%
DHalf in 2027, half in 2028≈ $223k (18.80m RUB)+26%

Level: projected — current rates (Tax Code art. 224) applied to the draft as described by the Ministry [S1, S3].

The general lesson. Tax deferral inside a wrapper is policy, not physics. The UK abolished its non-dom regime from April 2025; Russia now proposes to end fund-level deferral. If a structure's case rests mainly on deferral, re-run it without deferral — on the same assumptions as the alternatives.

Don't rush a sale for tax. A forced sale costs a discount: on a $6m building, every 1% off the price is $60k — about the whole tax difference between A and B in this example.

The conclusion is wrong if: the Duma keeps property sales in a separate base or adds a threshold; the minimum-holding-period exemption survives or widens; the start date slips past 1 Jan 2027; existing funds keep deferral under transition rules.

Four questions for your tax adviser (not individual advice): when will sale proceeds actually arrive (instalments, escrow)? Has the asset passed the minimum holding period? What does the structure look like without deferral? If a foreign company in the structure receives Russian dividends on type-"C" accounts — what does the proposed 35% profit-tax rate mean for it?

Review date: after the Duma's first reading, no later than 15 Nov 2026.

In Brief — forwardable

Russia's draft 2027 budget would tax property-sale gains and other passive income at up to 22% (from 15%) and make funds pay 15% on dividends, interest and rent as they arrive (reportedly qualified-investor funds only). Still a draft. If passed as is, tax on a large sale paid out in 2027 rises by roughly a third in our example, and spreading proceeds across years matters more. Don't rush a sale for tax without pricing the discount. Review after the first reading, by 15 Nov 2026.

Sources

Fee disclosure

Capital Desk is paid for by the client. Sdelio is my own product and brokerage arm: if a transaction goes through Sdelio, the commission from the deal is disclosed to the client in writing before the deal, together with a comparison against the no-commission option. The mandate success fee is paid by the client under the contract; if a counterparty pays any part of it, that is stated in the contract and disclosed before the deal.

This material is analysis, not individual investment advice, an offer or a formal valuation. Scenarios do not guarantee outcomes.