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A blacklist of offshore zones has been published in Russia.

On June 15, 2023, the List of States and Territories Providing a Preferential Tax Regime and (or) Not Providing for Disclosure and Provision of Information When Conducting Financial Transactions (Offshore Zones) was published, approved by Order of the Ministry of Finance of Russia dated June 5, 2023 No. 86n. It includes 91 jurisdictions and came into effect on July 1, 2023.

Features of the New Offshore List

It includes all jurisdictions that were included in the previously valid 2007 list, including classic offshore zones, as well as the United Arab Emirates.
The new list has more than doubled in size due to the inclusion of countries classified as unfriendly, including all countries of the European Union, Great Britain and all its overseas territories, Australia, Canada, Taiwan, the USA, Singapore, Montenegro, Switzerland and others. Thus, many jurisdictions, including those with tax treaties with Russia and always considered “white” or “onshore”, are no longer considered such from the point of view of the Russian financial authorities.
Among the EU countries, Cyprus and Malta “returned” to the offshore list, having been excluded from the previous list due to the conclusion or modernization of tax treaties with the Russian Federation.
The new list, like the previous one, does not include Hong Kong (a special administrative region of the PRC), but Macau remains.

Which countries are on the new blacklist?

  • Australia;
  • Republic of Austria;
  • Anguilla;
  • Antigua and Barbuda;
  • Aruba;
  • Belize;
  • Bermuda;
  • British Antarctic Territory;
  • British Indian Ocean Territory;
  • British Virgin Islands;
  • Brunei Darussalam;
  • Grand Duchy of Luxembourg;
  • Hungary;
  • Gibraltar;
  • Grenada;
  • Hellenic Republic;
  • Ireland;
  • Italian Republic;
  • Canada;
  • Macau Special Administrative Region of the People’s Republic of China;
  • Principality of Andorra;
  • Principality of Liechtenstein;
  • Principality of Monaco;
  • Kingdom of Bahrain;
  • Kingdom of Belgium;
  • Kingdom of Denmark;
  • Kingdom of Spain;
  • Kingdom of the Netherlands;
  • Kingdom of Norway;
  • Kingdom of Sweden;
  • Curaçao and Saint Martin (Dutch part);
  • Republic of Latvia;
  • Republic of Lithuania;
  • Labuan Island of Malaysia;
  • Republic of Maldives;
  • Montserrat;
  • New Zealand;
  • United Arab Emirates;
  • Cayman Islands;
  • Cook Islands;
  • Turks and Caicos Islands;
  • Separate administrative units of the United Kingdom of Great Britain and Northern Ireland:
  • Isle of Man;
  • Channel Islands (Guernsey, Jersey, Sark, Alderney);
  • Pitcairn;
  • Portuguese Republic;
  • Republic of Albania;
  • Republic of Bulgaria;
  • Republic of Vanuatu;
  • Republic of Iceland;
  • Republic of Cyprus;
  • Republic of Korea;
  • Republic of Liberia;
  • Republic of Mauritius;
  • Republic of Malta;
  • Republic of the Marshall Islands;
  • Republic of Nauru;
  • Niue;
  • Republic of Palau;
  • Republic of Panama;
  • Republic of Poland;
  • Independent State of Samoa;
  • Republic of San Marino;
  • Republic of North Macedonia;
  • Republic of Seychelles;
  • Republic of Singapore;
  • Republic of Slovenia;
  • Republic of Croatia;
  • Romania;
  • Saint Helena, Ascension Island, Tristan da Cunha;
  • Saint Vincent and the Grenadines;
  • Saint Kitts and Nevis;
  • Saint Lucia;
  • Slovak Republic;
  • Commonwealth of the Bahamas;
  • Commonwealth of Dominica;
  • United Kingdom of Great Britain and Northern Ireland;
  • United States of America;
  • Anjouan Island of the Union of Comoros;
  • Akrotiri and Dhekelia Sovereign Base Areas;
  • Taiwan (China);
  • Ukraine;
  • Federal Republic of Germany;
  • Federated States of Micronesia;
  • Republic of Finland;
  • Falkland Islands (Malvinas);
  • French Republic;
  • Montenegro;
  • Czech Republic;
  • Swiss Confederation;
  • Republic of Estonia;
  • South Georgia and the South Sandwich Islands;
  • Japan.

Why was a new list of offshore zones adopted?
The sharp expansion of the Russian “black list” is due to the deterioration of the situation with tax cooperation between Russia and countries classified as unfriendly. For example, countries such as the United States, Great Britain, Germany, Latvia, Switzerland and others have suspended or completely stopped cooperation with the Russian Federation in the tax sphere, and, above all, the exchange of tax information (automatic or within the framework of tax agreements).

A serious revision of approaches to classifying countries as “offshore” is also aimed at stimulating businesses to move to Russian jurisdiction or reorient them to cooperate with friendly countries.

In addition, one of the reasons for the formation of the new list may be a response to the inclusion of Russia in February 2023 in the European list of jurisdictions that do not cooperate in the tax sphere, which almost entirely consists of offshores.

What are the consequences of the Ministry of Finance’s “black list”?
The presence of a particular jurisdiction on the Ministry of Finance’s list excludes the application of a number of benefits for corporate income tax in the Russian Federation, and also affects some aspects of the rules on controlled transactions (transfer pricing) and taxation of profits of controlled foreign companies (CFCs).

Let us list these restrictions:

  • When a Russian company receives dividends from a foreign company from a “blacklisted” country, the Russian company does not have the right to use the 0% rate on profit tax (clause 3, Article 284 of the Tax Code of the Russian Federation).
  • The 0% rate cannot be applied to income from the sale of shares or participation interests in a foreign organization if its country of location is included in the “blacklist” of the Ministry of Finance (clause 4, Article 284.2 of the Tax Code of the Russian Federation).
  • Income in the form of property or property rights received free of charge by a Russian organization from a foreign subsidiary will be taxed if the permanent location of the transferring organization is a jurisdiction from the “blacklist” (subparagraph 11, clause 1, Article 251 of the Tax Code of the Russian Federation).
  • Transactions, one of the parties to which is a person from a “black list” country, are equated to transactions between related parties and are recognized as “controlled” if the amount of income from such transactions for a calendar year exceeds 120,000,000 rubles (clauses 1, 3, Article 105.14 of the Tax Code of the Russian Federation).
  • If the country of location of the CFC is included in the “black list”, then the exemption of CFC profits for active foreign holding and subholding companies will not apply in Russia (clause 7, Article 25.13-1 of the Tax Code of the Russian Federation).

By Order of the Ministry of Finance of Russia dated March 28, 2024 No. 35n, a special list of offshore zones for the period 2024-2026 was approved.

In the tax periods of 2024-2026, a special list of states and territories that provide a preferential tax regime and (or) do not require disclosure and provision of information when conducting financial transactions (offshore zones) is in effect, which is applied (Article 4 of the Federal Law of December 19, 2023 No. 595-FZ):

  • for the purposes of exemption from taxation of profits of controlled foreign companies in accordance with paragraph 3 of clause 7 of Article 25.13-1 of the Tax Code of the Russian Federation;
  • for adjusting the profits of controlled foreign companies in accordance with subparagraph 3 of clause 1.2 of Article 25.15 of the Tax Code of the Russian Federation;
  • to determine the tax base for corporate income tax in accordance with paragraph 3 of subparagraph 11, paragraph 1, Article 251 of the Tax Code of the Russian Federation;
  • for the application of tax rates for corporate income tax in accordance with subparagraphs 1 or 1.1, paragraph 3, Article 284 of the Tax Code of the Russian Federation. Thus, in accordance with subparagraph 1, paragraph 3, Article 284 of the Tax Code of the Russian Federation, when a Russian organization receives dividends from a foreign company, a zero rate is applied if (in particular) the permanent location of the foreign company is not an offshore zone. If dividends are received from a foreign company from an offshore zone, the income tax is calculated at a rate of 13% (subparagraph 2, paragraph 3, Article 284 of the Tax Code of the Russian Federation).


In pursuance of this provision, the Ministry of Finance of Russia, by order dated March 28, 2024 No. 35n (hereinafter referred to as Order No. 35n), approved the corresponding list of offshore zones. It includes the following 40 states and territories:

  • Anguilla;
  • Antigua and Barbuda;
  • Aruba;
  • Belize;
  • Bermuda;
  • British Virgin Islands;
  • Brunei Darussalam;
  • Gibraltar;
  • Grenada;
  • Principality of Andorra;
  • Principality of Liechtenstein;
  • Principality of Monaco;
  • Kingdom of Bahrain;
  • Curaçao and Saint Martin (Dutch part);
  • Republic of Maldives;
  • Montserrat;
  • Independent State of Samoa;
  • Niue;
  • Separate administrative units of the United Kingdom of Great Britain and Northern Ireland: Channel Islands (the islands of Guernsey, Jersey, Sark, Alderney) and the Isle of Man;
  • United Arab Emirates;
  • Anjouan Island of the Union of Comoros;
  • Labuan Island of Malaysia;
  • Cayman Islands;
  • Cook Islands;
  • Turks and Caicos Islands;
  • Republic of Vanuatu;
  • Republic of Liberia;
  • Republic of Mauritius;
  • Republic of the Marshall Islands;
  • Republic of Nauru;
  • Republic of Palau;
  • Republic of Panama;
  • Republic of San Marino;
  • Republic of Seychelles;
  • Saint Vincent and the Grenadines;
  • Saint Kitts and Nevis;
  • Saint Lucia;
  • Commonwealth of the Bahamas;
  • Commonwealth of Dominica;
  • Macau Special Administrative Region (Aomen) of the People’s Republic of China.


The new list is valid from 27.04.2024, but applies to legal relations from 01.01.2024.

We remind you that last year, the Russian Ministry of Finance, by order dated 05.06.2023 No. 86n, expanded the list of offshore territories to include 91 countries (see commentary). This list does not lose force in connection with Order No. 35n. However, for tax purposes in 2024–2026. it is necessary to be guided by Order No. 35n.

The article was prepared by lawyers of the “GeoBuro” company for their foreign subscribers and clients. The article was published on 15.08.2023.

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