Liquidation of a Russian company owned by foreign shareholders may require a permission of the government.
In accordance with the decree of the Russian president, the termination of the foreign (Europe, USA, etc.) ownership for the shares in a Russian company may need a permission of the governmental commission.
The Ministry of Finance issued a clarification with the list of cases when termination of the ownership for the shares is subject to permission. The list contains no case of liquidation but says that the permission may be required “in other cases”.
The lawyers of m|legal talked with Moscow notaries our law firm works with for many years: all of them confirmed that to start a liquidation of a foreign-owned company a permission of the governmental commission (or a letter that no permission is necessary) shall be filed to the notary.
The receipt of the permission may take weeks or even months. We recommend to consider the above when planning the liquidation of a Russian subsidiary.