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New Developments for Employers of Highly Qualified Specialists


Companies employing Highly Qualified Foreign Specialists (hereafter – HQS) must be aware of two significant changes that came into effect in the new year.

First of all, employers of HQS are no longer obligated to notify the migration services about registration for an HQS for tax purposes. Now local departments of the Federal Migration Service will confirm tax registration for the HQS through their own database. If the database does not contain information about the tax registration, the migration service will notify the tax authorities and the HQS will be registered and the information added to the database.

Second, there is finally a document specifying the order and, most importantly, a timeline of different notifications that employers of HQS must submit to the migration service that issued the work permit for an HQS. Here is the list and timeline of these notifications.


 The subject of notification What form must be submitted  Timeline 
Payment of declared salary (compensation) 

Annex #7 to the FMS Order #147 from June 28, 2010.

Note: This notification is finalized as of the last day of reporting period

 Quarterly, not later than last work day of the month following the end of the reporting period (quarter)
   Important – the legislation establishes minimum salary for most HQS as 2,000,000 rubles annually (including PIT)


(or) Granting HQS an unpaid leave for longer than 1 month per year

Annex #8 to the FMS Order #147 from June 28, 2010.  

  Within 3 workdays from date of granted leave or early termination of employment contract
(or) early termination of employment (civil-law) contract with HQS Annex #11 to the FMS Order #147 from June 28, 2010.

Failure to file abovementioned notifications according to prescribed timeline or prescribed form is punishable by fines:

  • For the company – 400,000-1,000,000 rubles;
  • For company’s chief executive – 35,000-70,000 rubles.


Moreover, some additional details of filling out and submitting notifications have been clarified:

  • Forms may be filled out by hand as well as on the computer. Most important, they must be filled in Russian, without abbreviations, acronyms and/or corrections;
  • Notifications may be submitted personally, via post or email, through The Internet Portal of Common Government Services. Electronic submissions will receive electronic confirmation not later than the following workday.


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