STABLECOINS AS AN OBJECT OF TAXATION: PROBLEMS OF QUALIFICATION IN RUSSIAN AND FOREIGN LAW
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Author(s): | Khusainov Z. F., Saveleva E. V., |
| Number of journal: | 2(75) | Date: | June 2026 |
| Annotation: | The article conducts a comparative legal analysis of the problems of qualifying stablecoins as an object of taxation in the Russian Federation and leading foreign jurisdictions (USA, EU, Singapore, China) in the context of the preparation of special regulation of crypto-assets effective from July 1, 2026. The legal nature of stablecoins is examined as a hybrid object combining features of a stable means of payment and an investment instrument, in light of the provisions of Article 1411 of the Civil Code of the Russian Federation and Federal Law No. 259-FZ. Under Russian law, stablecoins currently fall under the general rules applicable to digital currency or digital financial assets, giving rise to conflicts in the calculation of personal income tax (exchange rate differences, exchange, redemption), corporate profit tax, and VAT. The absence of special provisions in the Tax Code of the Russian Federation leads to risks of double taxation, uncertainty regarding the moment of tax liability, and insufficient protection for participants in cross-border settlements under conditions of foreign economic restrictions. A comparison with foreign experience shows that in the USA, stablecoins are classified as property subject to capital gains tax and strict reporting requirements; in the EU, unified reserve requirements and automatic data exchange have been introduced; in Singapore, there is no capital gains tax for individuals; in China, private stablecoins are banned in favor of the state digital yuan (e-CNY). The research results confirm the hypothesis on the need to single out stablecoins as a separate category with a special tax regime. Recommendations are aimed at introducing special provisions into the Tax Code of the Russian Federation: a separate article on stablecoins, tax benefits for personal income tax and VAT in payment use, a mechanism for crediting foreign tax, and a register of regulated tokens. The proposed measures will eliminate the risks of double taxation, increase tax certainty, and stimulate the legal use of stablecoins in cross-border transactions. | ||
| Keywords: | stablecoins, object of taxation, digital currency, tax law, Tax Code of the Russian Federation, MiCA, GENIUS Act, digital yuan, tax regime, comparative legal analysis, special regulation of crypto-assets |
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| For citation: | Saveleva E. V., Khusainov Z. F. Stablecoins as an object of taxation: problems of qualification in Russian and foreign law. Biznes. Obrazovanie. Pravo = Business. Education. Law. 2026;2(75):199—204. DOI: 10.25683/VOLBI.2026.75.1587. |
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