Since 1 January 2025, a foreign organisation that pays for work performed through Russian internet infrastructure can become an NDFL tax agent — which brings registration, withholding and reporting duties with it. Most foreign employers hiring remote workers in Russia have not checked whether this reaches them.
Hiring a remote developer in Russia does not by itself make you a tax agent. One route into the regime runs through Russian infrastructure — where the work is performed over the internet using any of the following:
The work is performed through resources on a .ru / .рф or other Russian domain.
The work runs through network addresses registered in the Russian segment of the internet.
The work uses information systems, servers or platforms physically located in Russia.
Infrastructure alone does not settle it. On this route the income also has to meet at least one of these:
For a foreign company with no Russian presence the third one falls away — which leaves residency and the payment account doing the work. A .ru domain on its own is not a verdict.
Art. 226(1.1) of the Russian Tax Code · in force since 1 January 2025
There is a second, independent basis. Alongside work performed through Russian infrastructure, the rules also reach remuneration for work, services or transferred rights performed by individuals over the internet regardless of where the work is physically done.
What limits it is tax residency: on this second basis the income sits outside Russia, so it becomes taxable — and the agent duty engages — where the person is a Russian tax resident. Which means the absence of Russian servers or a .ru domain does not, on its own, put you outside the regime.
Art. 208(1)(6.3) and Art. 208(3)(6.1), read with Art. 226(1.1)
Plenty of foreign employers are not agents: the work runs on your own systems outside Russia and the person is not a Russian tax resident. That combination is common, and it is a real answer — we would rather give it than sell you a registration you do not need.
But the line is fine, and residency can change mid-year without anyone telling you. If you cannot confirm a person's status, treat that as unresolved rather than as a clean answer — it is worth having the conclusion in writing either way.
This is the part most analyses skip. The agent duty does not always rest with the company whose money it is — the payment route matters, and in one common arrangement it lands somewhere else entirely.
The duty, if it arises, sits with you as the foreign payer. This is the ordinary case.
Where a Russian organisation provides the organisational, informational or technical means for the payment, that organisation can itself become the tax agent — and the duty may not be yours at all.
Banks, payment-system participants and telecom operators are not treated as agents merely for moving the money. A payment rail does not shift the duty.
Art. 226(1.1), paragraphs two and three
You are about to pay someone for work performed through Russian infrastructure.
The application to register goes in no later than the date of the first payment on which you act as agent.
NDFL is withheld from each qualifying payment at the rate for that income level.
Tax is remitted and reporting filed on the Russian calendar, through the taxpayer's personal account.
Registration duty: Art. 83(4.10) of the Russian Tax Code
NDFL is no longer a flat rate. For the relevant NDFL base these progressive thresholds apply, and the band depends on the amount paid across the year — so withholding on the same person can change partway through it.
Worth being precise about what this scale is: it applies to income of the kind described above — including where the recipient is not a Russian tax resident. The default 30% rate that applies to many other non-resident earnings does not displace it here. It is not, however, a universal grid for every payment you make.
Art. 224(3.1) of the Russian Tax Code · thresholds apply to the relevant NDFL base, not to every payment
Not registering does not pause the obligation — it accumulates quietly behind the payments you have already made. Unwithheld tax stays owed, late payment attracts interest, and failing to register or to perform agent duties carries its own consequences on top.
The practical point: a period you come forward about voluntarily is handled very differently from one found for you. If you have been paying people in Russia for a while without looking at this, that is worth quantifying now rather than later.
We prepare and file the application to register you as a tax agent, before your first qualifying payment.
Withholding calculated per payment, tax remitted, reporting filed, personal account maintained — on a fixed fee.
If payments have already been made, we quantify the period and structure the disclosure.
The agent question rarely arrives alone. The form of the relationship affects the tax treatment, the paperwork and the risk of the arrangement being recharacterised later — and it is far easier to set up correctly than to unwind.
Familiar to foreign employers, but with people working from abroad it tends to carry more regulatory and documentary risk than the alternatives — and warrants a look at the facts.
The commonly advised structure — with its own documentation and recharacterisation risk.
Lower rates, but strict conditions, and the arrangement has to genuinely fit them.
The rule is addressed to foreign organisations, so a foreign sole trader or private individual paying a contractor does not fall under it in the same way. That does not automatically mean nothing is owed by anyone — the recipient may still have their own filing obligation — but the agent duty described on this page is not yours. Worth confirming in writing if the arrangement is sizeable or ongoing.
Establish whether the work will run through Russian infrastructure — that is what decides it. If it does, the registration application goes in no later than the date of that first payment, so the sequence matters: check first, register, then pay. If it does not, you have nothing to file and it is worth having that conclusion documented before the arrangement grows.
Not automatically. The test is not where the person sits — it is whether the work is performed through Russian internet infrastructure: a Russian domain name, a network address in the Russian segment, or hardware and software hosted in Russia. A developer working on your own foreign systems is a different case from one working inside a Russian platform. This is the distinction worth getting in writing before your first payment, not after.
It depends on where the work is actually performed and who is treated as paying the income. A payment routed through a foreign intermediary does not by itself remove a Russian agent duty, and some platform arrangements shift it rather than end it. We map the chain and tell you where the obligation sits — with you, with the platform, or nowhere.
Yes — being a tax agent does not require setting up a Russian company. A foreign organisation registers with the Russian tax authority, then withholds, remits and reports. The mechanics of doing that from abroad are a separate question from whether it is possible, and they are part of what we handle. Registration comes before the first payment on which you act as agent.
Paying Russian tax from abroad has working routes, and the payment mechanics are part of what we handle rather than something we leave with you. It is a solvable problem — but one worth solving before the deadline, not at it.
The duty accrues from the first qualifying payment, so unregistered periods leave unwithheld tax and accruing exposure behind them. Coming forward voluntarily is materially better handled than waiting to be found. We assess the period, quantify it and structure the catch-up.
It changes both the tax treatment and the risk of the arrangement being recharacterised later. The form of the relationship is a structural decision, not just paperwork, and it is easier to set up correctly than to unwind. We advise on the choice alongside the agent question.
This work sits with our payroll and cross-border team — the same people who run monthly Russian payroll for foreign-owned companies, reported in English. Your engagement letter names your adviser, and every filing carries their sign-off.
Big Four background, based in Moscow, working with international clients since 2018. You always know who to call.
Tell us how the work is performed and how you pay for it. If the agent duty doesn't reach you, we'll say so plainly.
ex-Big Four team · Moscow · since 2018 · © TaxWell & Partners
Practical support for international business in Russia.