Saudi Arabia Company Setup from Russia 2026: CFC, Banks

Saudi law has no rule for Russian founders. The Investment Law treats a Russian owner like any other foreign owner, and the central bank's account rules name no nationality.

What is specific to this route sits elsewhere: in a 2007 tax treaty, in the Russian Tax Code, in a Bank of Russia threshold, and in the risk policies of banks that clear in US dollars.

This page keeps the Saudi side short and spends its length on those four.

5%treaty cap on dividends, the same as the Saudi domestic rate

18.75%effective tax rate a Saudi company needs to be exempt from Russian CFC tax

RUB 30mpayable into one foreign company without individual Bank of Russia permission

90 daysvisa free stay per calendar year since 11 May 2026, work excluded

Two readers, two different files

A Russian passport is the same in both cases. Almost everything else differs, because Russian tax and currency rules follow residence.

Tax residence and currency residence are separate tests. Leaving Russia can end one without ending the other. Have both confirmed before you rely on the right hand column.

The rest of this page is written first for the resident of Russia. The Gulf based reader has a section near the end.

What Saudi Arabia asks of any foreign founder

Three points from the Saudi guides decide most plans. They are summarised here and not redeveloped.

• Who can apply. The ministry registers legal entities, foreign companies and individuals holding Premium Residency. An individual without a company has the entrepreneur track, with a support letter from a Saudi university or an accredited incubator.
• What the company does. Services, consulting and software carry no published capital figure. Trading at full foreign ownership needs SAR 30,000,000 of capital.
• Who runs it. The shareholder can stay abroad. The general manager is expected in practice to hold an iqama.

The detail is in 100% foreign ownership in Saudi Arabia, and the filing sequence in how to register a company in Saudi Arabia.

For a Russian exporter, the trading line is the first obstacle. A company that imports and resells food or building materials is a trading company. The published alternative is a Saudi distributor plus a scientific and technical office, which supports the product and may not sell.

Entering the Kingdom: what visa free does not cover

The visa exemption agreement between Russia and Saudi Arabia entered into force on 11 May 2026. The Russian Foreign Ministry summarises it in one sentence.

• 90 days per calendar year without a visa.
• Not for permanent residence, study or work.
• Not for Hajj, nor for Umrah during the Hajj season.

That is enough to meet partners, visit a bank and sign documents. It does not let you manage the company on the ground. A general manager still needs an iqama, issued on the commercial register that names the manager.

The 2007 tax treaty: in force, and narrower than it sounds

Russia and Saudi Arabia signed a tax convention in Riyadh on 11 February 2007. The Saudi tax authority's list of agreements gives its entry into force as 1 February 2010, and Russian reference tables show it applied from 1 January 2011.

It is not suspended. Presidential Decree No. 585 of 8 August 2023 suspended most articles of 38 Russian tax treaties, citing unfriendly actions by the states concerned. We read the list in full. The Saudi convention is not on it.

A treaty sets a ceiling, and on dividends and interest the Saudi rate already sits at that ceiling. Three things in the treaty still matter.

• Royalties. A licence fee paid to a Russian resident is capped at 10% (Article 12), against 15% without a treaty.
• Services. Staff sent to the Kingdom create a permanent establishment only beyond six months in any twelve, counted per project (Article 5).
• Credit in Russia. Russia deducts the Saudi tax from its own tax on the same income, up to the Russian amount (Article 24).

The dividend itself is paid out of profit already taxed at 20% in the company, so the combined Saudi charge on distributed profit is 24%. The calculation and the relief procedure are in Saudi Arabia withholding tax for non-residents.

Russian CFC rules: the 18.75% floor

Chapter 3.4 of the Russian Tax Code taxes a Russian resident on the undistributed profit of a foreign company he or she controls. A wholly owned Saudi company is such a company.

1. 1
   Are you a Russian tax resident?If not, Chapter 3.4 does not apply to you
2. 2
   Do you hold more than 25%?Or more than 10% where Russian tax residents together hold more than 50%
3. 3
   Is the company's profit above RUB 10,000,000 for the year?Below that, the profit is not added to your tax base
4. 4
   Is the effective tax rate at least 18.75%, or is the company active?Active means passive income is no more than 20% of total income
5. 5
   File the notifications in every caseParticipation within three months, then the yearly CFC notice

The effective rate exemption is where Saudi Arabia is unusual. Article 25.13-1 exempts a company whose effective rate is at least 75% of the weighted average Russian rate. With the Russian profit tax at 25%, that floor is 18.75% on operating profit.

Saudi income tax on the foreign owned share20%

Russian exemption floor18.75%

Regional headquarters, eligible income0%

Three cautions follow from the text.

• The test is on tax actually computed, measured against the company's profit. Deductions and timing differences can pull a nominal 20% under 18.75%.
• Incentive regimes fail it. A regional headquarters or a special economic zone company with a reduced rate must rely on the active company test instead.
• A treaty is a condition. Paragraph 7 grants this exemption only where Russia has a tax treaty with the state and the state is not on the list of those without exchange of tax information. The treaty exists, and Saudi Arabia is not on the list.

Two Russian lists are often confused at this point. Saudi Arabia is on neither, as read on the official legal information portal on 5 October 2026.

• States without exchange of tax information. Federal Tax Service Order No. ED-7-17/914@ of 30 October 2024, with 117 states and 14 territories. This is the list paragraph 7 refers to, so it conditions the effective rate exemption.
• Offshore zones. Ministry of Finance Order No. 86n of 5 June 2023, with 91 entries. It conditions the exemption of active holding companies for periods from 2026 and several other rules of the Code, not the effective rate test.
• Both are revised. Check the edition in force for the year whose profit you compute.

The Saudi rates behind that chart are explained in Saudi corporate tax and zakat.

The Russian filings, with their dates

An exempt company is still a declared company. The fines apply to the notice, not to the tax.

The last line concerns an account in your own name. The Saudi company's account belongs to the company, and its reporting follows Saudi rules.

The CFC notice falls a year later than most summaries say. Article 25.15 fixes the controlling person's share of the profit at 31 December of the year after the company's financial year ends, where no distribution is decided. Article 25.14 places the notice in the year after that. For a Saudi year closed on 31 December 2026, the notice is due by 20 March or 30 April 2028.

This is a literal reading of the two articles. Confirm your first filing year with a Russian tax adviser.

A Russian company that controls the Saudi one pays 25% on any CFC profit that is not exempt. For an individual controller, rates and the fixed profit option should be checked with a Russian adviser.

Moving the capital out of Russia

A Russian resident paying for shares in a foreign company has needed Bank of Russia permission since 2022. A general permission now covers most small and mid sized projects.

• RUB 30 million per foreign company without individual permission, from 1 July 2026. The earlier ceiling was RUB 15 million.
• Cumulative, not annual. Every payment to the same company since 1 April 2024 counts.
• Rubles or foreign currency, converted at the official rate on the payment date.
• Above the ceiling, an individual permission from the Bank of Russia is required.

For a services company this is rarely binding, because Saudi Arabia publishes no capital floor for services. For trading it is decisive: SAR 30,000,000 is about USD 8 million at the riyal's peg, far above the general permission.

Test the payment route with a small transfer before any Saudi deadline starts. A rule that permits a transfer does not oblige a bank to carry it.

Banking: what the rule says, and what is only claimed

This is the most sensitive part of the route, and the part with the least evidence.

The risk is real even without a Saudi rule. The riyal is pegged to the US dollar, and dollar payments clear through correspondent banks. Since December 2023 the United States can sanction a foreign bank over certain Russia related business.

OFAC's guidance says a foreign financial institution may be sanctioned for significant transactions for persons blocked under the Russia programme. It adds services to persons operating in five sectors of the Russian economy.

• Technology.
• Defence and related materiel.
• Construction.
• Aerospace.
• Manufacturing.

A Saudi bank reads that list when it sees a Russian owner. The result is bank policy, which varies and is not published. Ask the bank in writing what it needs from a Russian beneficial owner before you incorporate. The account rules are in business bank account in Saudi Arabia.

Documents from Russia

The regular application expects a corporate applicant, so most Russian projects apply through an existing Russian company.

• Commercial register extract of the Russian company, certified by the Saudi Embassy.
• Financial statements for the last fiscal year, certified the same way. A company formed last month does not have them.
• Apostille. Russia and Saudi Arabia are both parties to the Apostille Convention, Saudi Arabia since 7 December 2022. The investment ministry's guide still names the embassy, so confirm which one your file needs.
• Translations into Arabic, to the standard the ministry accepts.

If you already live in the Gulf

For a Russian citizen resident in the Gulf, most of the Russian side changes.

• CFC rules stop with tax residence. Chapter 3.4 applies to Russian tax residents only.
• The treaty changes. You claim under the treaty between Saudi Arabia and your country of residence, not the 2007 convention.
• The applicant is usually your Gulf company, which has a register extract and accounts to certify.
• A Gulf company does not make you local. A GCC investor is treated as local unless foreign investors sit in its ownership structure.
• The bank still sees a Russian beneficial owner. Residence abroad does not change that part of the file.