The Russian Duma has just introduced law #140-FZ, which proposes to implement a voluntary disclosure programme for all Russian citizens, irrespective of their tax residencies.

The new programme allows for the disclosure of foreign and Russian assets, including real estate, shares etc. owned directly by the taxpayer or via a nominee, foreign bank accounts, and Controlled Foreign Companies.

This follows last year's efforts to capture tax on foreign assets and company ownership and to stem the 'offshorisation' of Russian money. There is to be no requirement for disclosure participants to declare all assets. They will be guaranteed freedom from prosecution and will "receive exemptions" from criminal, tax and administrative liability for a number of offshore tax violations committed before 1 January 2015.

Russian tax-resident high-net-worth individuals should consider taking advantage of the programme as soon as possible to disclose assets or bank accounts; make tax free transfers of assets from nominees to the beneficial owner; and to liquidate foreign legal entities or structures before 1st January 2017 to receive these assets tax-free. Their advisors and private bankers might urge them to do so.

Non-Russian residents should also use the programme to regularise any compliance issues and trustees of foreign trusts or foundations with Russian resident settlors, beneficiaries or controlling persons should also seek advice on their circumstances, as they may receive requests from clients to participate in the programme.