Tax Incentives in Exchange for Actual Investment

The amendments to the Russian Tax Code introduced by Federal Law No. 18-FZ of 11 February 2026 have laid the groundwork for limiting the amount of tax relief available under certain preferential investment regimes.

Eligibility for these tax incentives will depend on whether investors actually fulfil their project commitments, particularly those relating to capital investment and research and development (R&D) expenditure.

The new rules will apply to the following existing preferential regimes:

• Territories of Advanced Development (TADs), including International Territories of Advanced Development (ITADs)
• The Free Port of Vladivostok
• The Arctic Zone of the Russian Federation
• All special economic zones (SEZs), including the Special Economic Zone in the Kaliningrad Region
• The Free Economic Zone in Crimea and Sevastopol

These preferential regimes were established at different times and are governed by separate laws. To address the resulting patchwork of regulations and establish a consistent approach to tax incentives, the legislature has introduced a new Article 56.1 into the Russian Tax Code, providing an overarching legal framework applicable to these regimes.
 

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