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Market entry · 4 min
Updated January 2026
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Restructuring Russian Operations: Legal

A practical guide to restructuring Russian operations in 2026 — the four main approaches (sale, liquidation, operational wind-down, intragroup transfer)…

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Restructuring Russian operations is rarely a straightforward decision. The choice between selling, liquidating, winding down or transferring ownership involves regulatory approvals, tax consequences, employee obligations, customer and supplier relationships, and in some cases political risk. The right answer depends on whether the company is from an "unfriendly" jurisdiction, the value and nature of the Russian assets, the timeline available, and the group's objectives.

This article covers the four main options, their practical implications, the sequencing decisions that determine success, and the forced seizure risk that has made inaction increasingly dangerous.

The landscape in 2026

The forced seizure risk has changed the calculus for companies that were previously content to maintain a dormant presence while waiting for conditions to improve. Rockwool and CanPack — companies with decades of Russian history and no active plans to exit — found their assets placed under Russian government control in 2025. The message is clear: dormant entities in strategic or politically sensitive sectors are not safe from intervention.

The four main options

Friendly vs unfriendly jurisdiction — the key distinction

The most important variable in any Russian restructuring is whether the company is from a jurisdiction Russia classifies as "unfriendly." This determines whether Sub-Commission approval is required, whether the mandatory discount and exit tax apply, and what the realistic exit proceeds will be.

Unfriendly jurisdictions (EU, US, UK, Canada, Japan, Australia, Singapore, South Korea, Switzerland, Norway): Sub-Commission approval required, 60% mandatory discount, 35% exit tax, presidential approval above RUB 50 billion. Realistic proceeds: 20–40% of market value

Friendly jurisdictions (Turkey, UAE, China, India, Brazil, CIS countries, most of Asia, Africa and Latin America): no Sub-Commission approval required for most transactions, no mandatory discount, no exit tax, normal commercial deal terms. Realistic proceeds: full market value

Companies from friendly jurisdictions — Turkish, UAE, Chinese, Indian — can acquire Russian businesses from unfriendly-jurisdiction sellers at highly discounted prices. The seller accepts 20–40% of value to exit; the buyer pays a fraction of market value for a functioning Russian business. This dynamic has driven a significant portion of the exit deals completed since 2022 and continues to create acquisition opportunities for well-positioned buyers from neutral countries.

Forced seizure risk — understanding the threat

Russia's forced seizure mechanism — technically called "temporary administration" (временная администрация) — allows Russian courts to appoint an external administrator over a foreign-owned business in certain circumstances. The legal basis has expanded since 2022.

The companies most exposed to forced seizure risk are those that:

Have suspended operations but retained the legal entity without a clear exit plan

Operate in sectors deemed strategically important (energy, defence, critical infrastructure, food production)

Have significant Russian assets or market position that would be valuable to a domestic acquirer

Have publicly announced an intention to leave without completing the exit process

Are associated with jurisdictions that have taken the most aggressive sanction positions against Russia

The cases of Rockwool, CanPack and others in late 2025 demonstrated that even companies with no intention to antagonise Russian authorities are not protected if their assets are considered valuable enough to attract attention. A Russian company with positive net assets, functioning infrastructure and a Russian workforce — even if not actively trading — can be a target. The trend is toward more, not fewer, forced interventions in 2026.

Voluntary liquidation — the process in detail

Step by step

Sequencing — what to do first

The order in which restructuring steps are taken matters significantly. Common sequencing errors:

Announcing exit before completing it — public announcements of exit intention attract regulatory attention and can accelerate forced seizure proceedings. Maintain discretion until the transaction or process is substantially complete

Stopping compliance before the entity is deregistered — even a dormant entity must file tax returns, accounting reports and corporate registrations. Stopping compliance while the entity still exists creates additional problems

Dismissing employees before the liquidation is funded — employee termination payments are priority creditor claims in liquidation. Ensure the entity has sufficient cash to fund all termination costs before initiating the process

Not addressing intercompany obligations first — intercompany loans owed by the Russian entity to the parent may be treated as claims in liquidation. Structure these carefully before initiating

Ignoring the tax audit risk — the mandatory tax audit can result in additional assessments. Conduct a pre-liquidation tax health check to identify and resolve potential issues before the liquidation audit begins

Practical checklist

Determine whether Sub-Commission approval is required — assess jurisdiction status

If unfriendly jurisdiction: assess realistic net proceeds after mandatory discount and exit tax

Consider intragroup transfer to a friendly-jurisdiction entity as a first step

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