Is it permissible to pay salaries to foreign citizens who are non-residents?

Territorial jurisdiction:

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Russia

Short answer:

Yes, but it is more appropriate to formalize such payments as remuneration under a civil law contract rather than as a salary.

Denis Polyakov GMT Legal

Denis Polyakov

Head of Digital Economy practice at GMT Legal

Payments to foreign nationals who are not tax residents of the Russian Federation are possible and lawful. However, in most cases, it is more appropriate to formalize such payments not as salary, but as remuneration under a civil law contract. This is because employment relationships generally imply the performance of work within the territory of the Russian Federation, whereas in the case of non-residents, it usually concerns the provision of remote services or performance of work governed by the terms of international agreements (such as double taxation avoidance agreements). This approach helps avoid legal conflicts related to the territorial scope of labor law and more accurately reflects the nature of the relationship with the foreign contractor.

June 22, 2025

June 22, 2025

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