Tax and legal framework for the ruble-backed stablecoin A7A5 within the digital rights system of the Russian Federation

Abstract

The article is devoted to the study of the tax and legal aspects of the ruble-backed stablecoin A7A5, which is a foreign digital right and is qualified in the Russian Federation as a digital financial asset. The subject of the study is the specifics of the legal regime of foreign digital rights classified as digital financial assets in the Russian Federation, and the taxation of transactions with such an asset. As a result of the conducted research, the author comes to the conclusion that, despite the creation of a legal framework for the integration of foreign digital rights into the Russian legal order, their tax and legal regime remains insufficiently developed. It is shown that this category is of an auxiliary (technical) nature and serves primarily as a tool for legitimizing a certain range of foreign assets in Russia, without being a full-fledged and independent legal construct. It is noted that the Tax Code of the Russian Federation lacks special provisions regulating the taxation of foreign digital rights, except for transactions within the experimental legal regime, which creates legal uncertainty. The author argues that recognizing foreign digital rights as digital financial assets represents a new phase in Russia's digital financial assets market, driven significantly by the A7A5 asset's integration with a public blockchain. This not only expands the opportunities for the circulation of such assets but also gives rise to unique transactions with such assets in the decentralized finance environment, which directly raises the issue of the need to develop special approaches to accounting for income, expenses and losses from such transactions for tax purposes. It is concluded that the economic nature of such transactions may be similar to transactions with derivative financial instruments and hedging. This similarity justifies extending the special tax rules for such analogous instruments to transactions with foreign digital rights. The results of the study can be applied to the further development of legislation on the taxation of foreign digital rights.