Exit, hold or re-enter — each is a different plan. The suspended treaty raises the cost of all three.
The Russia–Japan double tax treaty is suspended under Decree 585. Where relief was previously available, the domestic rate now applies — which affects dividends, interest and royalties flowing to the parent, and often changes whether holding the position still makes sense.
This is where most groups from your region actually get stuck. Settlement routes are narrower, correspondent banking is cautious, and funds that reach a Russian account are subject to currency control and, for owners from designated jurisdictions, authorisation limits on the way out. The route has to be planned rather than assumed.
For a group reducing presence, employment sequencing matters more than headcount: dismissal requires a Labour Code ground and a documented procedure, and claims outlive the entity.
Corporate, commercial and regulatory support.
Doing nothing has a cost that accrues quietly — dormant entities still file, still need directors, and still cost more to unwind later than now. The choice is worth making deliberately.
More than closing an entity. A clean exit means settling tax and reporting up to the exit date, clearing employee obligations properly, dealing with the sale or transfer of assets, and — where the buyer or structure requires it — the government commission approval that applies to disposals by parties from countries deemed unfriendly. The suspended treaty means dividend and asset flows out are taxed without relief, so the sequence and structure of the exit materially affect what reaches Japan. We plan it so it closes cleanly rather than leaving a tail of Russian obligations.
Yes. A dormant Russian company still files statutory accounts and tax returns, maintains its registration, and remains subject to audit — dormancy is not absence of obligation, and unfiled years accumulate penalties that surface when you eventually exit or reactivate. If funds are held in a Type-C account, access is restricted but the reporting continues. We keep a held structure compliant and inexpensive to maintain, so it is ready to either exit or restart without a backlog to clean up first.
For some sectors, yes, and the competitive logic is real: as established suppliers withdraw, the ones who stay or return face less competition for the same demand. The tax and operational picture is different from the pre-2022 one — CIT is 25%, the treaty is suspended, banking and payments need planning — but none of it is prohibitive with the structure built for today's rules. We model the position honestly, including the downside, so the decision is made on facts rather than either optimism or fear.
Hold, restructure or exit — each has a different tax outcome and timeline. We model them side by side.
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