The August 2024 Presidential Decree provided to the investors an opportunity to have the Eurobonds issued by Russia’s Ministry of Finance replaced (Decree of the President of the Russian Federation No. 677 dated 8 August 2024). This step was made because the imposed sanctions did not allow the Eurobond holders to receive coupon payments.

For the purposes of the above-mentioned Presidential Decree, the Ministry of Finance developed the terms for the so-called “replacement” of its Eurobonds (Order of the Ministry of Finance of the Russian Federation No. 388 dated 5 September 2024).

The VERBA LEGAL tax practice team consisting of Counsellor Evgeniya Zainchukovskaya, Senior Associate Andrey Sheptiy and Paralegal Altana Lidzhieva explains the essence of substitution and its tax consequences.