Russia: Property Transactions with Non-Russian Residents Now Require Special Permission

A new special procedure for real estate transactions involving non-Russian residents has gone into effect. In a transaction where one of the parties (applying to both an individual or a legal entity) is associated with a state deemed “unfriendly” to Russia, the parties must now obtain special permission from the Government Commission for the Control of Foreign Investments in Russia in order to complete the transaction. Association is defined as citizenship, residency registration, primarily conducting business or making profit, or controlling a Russian company through shares or direct management. Real estate transactions are defined as sales and purchases, gifts, in-kind transactions, rent, and participation in construction of co-funding or cooperative housing. To secure the necessary special permission, a participant of the transaction must submit an application to the subcommittee appointed for this purpose. The application must be signed in person and must also be notarized if the applicant is an individual and not a legal entity.