Decree No. 254 · 4 May 2022

Dividends and profit distributions to unfriendly participants

Extends the type C regime to corporate payouts: distributions of profit to participants from unfriendly states above RUB 10 million a month go to a type C account.

What it does

Decree No. 254 governs the performance of financial obligations in corporate relations — above all the distribution of profit of LLCs, partnerships and cooperatives — to foreign participants connected with unfriendly states. Up to RUB 10 million per month may be paid normally; above that, payment is made in roubles into a type C account, or under a permit of the Government Commission or the Bank of Russia. Payments to such participants controlled by Russian persons with disclosed control, or by friendly persons whose control predates 1 March 2022, are outside the regime.

Since 30 October 2024, under Bank of Russia Clarification No. 4-OR, a resident's obligation to distribute profit may also be terminated by set-off where a Bank of Russia or Government Commission permit covers it. Permits to pay dividends above the cap are granted on the Government Commission's published conditions (not more than 50% of the previous year's net profit, among others).

Status, October 2026

In force, without an end date.

Operations that rest on it

Guides that discuss it

How Russian counter-sanctions work: decrees, the Government Commission and the Bank of Russia

Who issues what, which instruments actually bind a bank, and why the answer to a simple question is usually spread across four documents.

Dividends from a Russian subsidiary to a shareholder in an unfriendly state

The RUB 10 million monthly cap, type C accounts, the two routes to a permit, and the one structure that avoids the regime altogether.

Type C accounts: what goes in, what can come out, and the 2026 changes for deposits

The mechanism behind every “RUB 10 million per month” rule — who must use it, what a balance can be spent on, and what Decrees No. 377 and 550 did this year.

Intra-group loans with a Russian subsidiary: granting, repaying and the permit line

Which direction of lending is free, which needs a permit, how repayment to a Western lender works above RUB 10 million, and the new RUB 30 million limit for capital contributions.

Decree No. 618: getting a Government Commission permit for a transaction with a Russian LLC interest

What needs a permit, what does not (including the 2025 and 2026 Ministry of Finance clarifications), what goes in the file, how long it takes and what happens at the notary.

The Russian-control exception: disclosing control to the Federal Tax Service and what it unlocks

The one lawful way out of the “unfriendly” regime for a foreign company owned by Russians — the CFC notification, the tax office confirmation under Letter ShYu-4-13/13043@, and the decrees it switches off.

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