Resident race: 135 more companies moved to "Russian offshore companies" in 2025
Last year, 135 more organizations moved to Russian offshore companies, the Ministry of Energy told Izvestia. Among the big ones are Etalon and Ozon. Those who passed this procedure turned out to be a third less than a year earlier, but so far the transition process is often delayed due to prolonged exclusion from foreign registries. Businesses are still interested in special administrative regions (SAR): it is easier to work there due to the benefits. In addition, the recently simplified relocation was extended for another year. As early as 2026, the O'key Group may also move to Russian offshore companies, experts say.
How many companies work in the SAR
By the end of 2025, 674 companies were registered in the SAR, 148 of them residents on Oktyabrsky Island (Kaliningrad Region) and 526 on Russian Island (Primorsky Territory), the press service of the Ministry of Energy told Izvestia. In total, 135 participants from foreign jurisdictions moved to Russian offshore companies last year (103 to Oktyabrsky, 32 to Russian).
Special administrative regions are territories where a simplified tax and currency regulation regime is in effect. It is suitable for companies that have decided to transfer from a foreign jurisdiction (most often from Cyprus or the Netherlands) to a Russian one. ATS appeared in Russia in 2018. Their main goal was to deoffshorize foreign holdings controlled by Russian citizens.
Until 2022, residents in the SAR appeared slowly — in 2019 there were 22 of them, in 2022 - 83. According to the Ministry of Energy, 200 new participants registered in these zones in 2023, and 190 organizations in 2024. At the same time, some companies could eventually move from the SAR to other regions of Russia.
— The main flow of companies occurred in 2022-2024, when businesses were rapidly transferring holding structures from foreign jurisdictions. By 2025, this "pent-up demand" has largely been realized, and the market has entered a quieter phase," explained Sergey Katyrin, head of the Chamber of Commerce and Industry of the Russian Federation.
Last year, the flow decreased due to the effect of the high base of previous years, said Vladimir Chernov, analyst at Freedom Finance Global. However, the mechanism is not closed — the government continues to extend and upgrade it, because demand persists.
In addition, it is important to take into account the qualitative composition of the relocating companies, Ekaterina Kosareva, managing partner of the VMT Consulting agency, pointed out. Large and financially stable structures mainly enter the SAR: holdings, industrial groups, companies with export earnings and complex corporate architecture. For them, redomicilation is not just a change of address, but an expensive and legally complex process that requires strong financial, legal and managerial resources, she added.
This process is often lengthy, as the key stage in it is the exclusion from the foreign registry, explained Vladimir Chernov. Russia cannot influence this, therefore, according to the documents, some of the enterprises are moving later than planned.
In 2025, for example, the Ozon marketplace, the Cian real estate aggregator and the Etalon developer were registered in these zones. Izvestia sent them a request — Ozon and Cyan confirmed the fact of redomicilation. Earlier, the move was made by Yandex, HeadHunter recruiter, and the Mother and Child clinic network. There is no complete list of organizations that are registered in administrative districts in the public domain.
Tax regime in the SAR
Active interest in the SAR arose from Russian structures back in 2022. It was difficult for companies to settle accounts with their foreign holding companies, explained Vitaliy Ivanenko, partner of the audit and consulting group Unicon. Then the authorities introduced a simplified redomicilation procedure for organizations. It made it possible to increase the number of new residents by almost 2.5 times in 2023. Recently, this measure was extended until the end of 2026.
According to the press service of the Ministry of Energy, the attractiveness of the ATS for business is primarily related to tax and corporate advantages. Companies will be able to re-register in Russia while maintaining their corporate structure, receive income tax and dividend benefits, and relax currency controls.
In particular, the tax benefits provide for a five percent tax on income in the form of dividends, 5% on income earned by foreign individuals in the form of dividends on shares of international holdings, as well as exemption from income tax on income from the sale of shares of foreign companies, said Vasily Kutyin, Director of Analytics at Ingo Bank.
In addition, the "relocation" to these areas allows to preserve the succession, assets, contracts and corporate structure, he added. They also do not pay transportation tax and property tax. To receive benefits, an organization registered in the SAR must have the status of an international holding company (IHK), said Vitaly Ivanenko.
Which companies will move to "Russian offshore companies"
The main Russian companies and holdings have already been redomiciled, so in 2026-2027 up to 100 organizations may become residents of the SAR, says Dmitry Tselishchev, managing director of the Rikom-Trust investment company.
One of the most obvious candidates, those who publicly supported the move, is the O'key Group store chain, said Vladimir Chernov from Freedom Finance Global. Shareholders approved the redomicilation from Luxembourg back in March 2025, he added. Izvestia sent a request to the company.
ATS remain relevant, despite the fact that fewer companies moved to them in 2025 than a year earlier. Nevertheless, the regime should be supplemented with new preferences, says Alexey Khizhnyak, GR Director of the Mikhailov and Partners Law Firm. For example, the Ministry of Finance has prepared a bill that proposes to exclude from the income tax base transactions for the acquisition and transfer of shares of companies — residents of the SAR to their employees.
According to the expert, the release is possible provided that the securities were acquired during the additional issue specifically for the motivation program and they were not transferred to third parties before being transferred to employees.
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