What tax obligations arise for a company upon the issuance of digital financial assets (DFA)?
Territorial jurisdiction:
Russia
Short answer:
Tax obligations depend on the conditions for exercising rights related to the digital financial assets (DFA) and the timing of their redemption.

Denis Polyakov
Head of Digital Economy practice at GMT Legal
When issuing Digital Financial Assets (DFA), the tax consequences for the issuer are determined based on the nature of the rights granted by the DFA and the mechanism for their execution. In particular, it is important to consider: • The type and procedure for the realization of rights under the DFA — if the digital asset grants property rights (for example, the right to receive income), then income received from its realization or fulfillment is subject to taxation in accordance with the general rules for profit taxation. • The moment of redemption of the DFA — this is the point at which a tax base may arise, for example, if the transfer of assets, funds, or the provision of services occurs to fulfill obligations under the DFA. In each case, the tax classification of operations with DFA requires individual analysis, and companies are advised to consider tax risks in advance when developing the structure of the issuance and the terms of circulation of the DFA.