Cryptocurrency Mining Tax in Russia: Corporate Profit Tax for Mining Companies

How is cryptocurrency mining income taxed for a foreign-owned company in Russia?

For a foreign-owned Russian company, cryptocurrency mining tax in Russia follows the same rules as for other Russian legal entities. Mined cryptocurrency forms part of a separate corporate profit tax base and is taxed at 25%. Income is recognized when the company obtains the right to dispose of it and is valued using the applicable market quotation. Eligible expenses may reduce the tax base, while the subsequent sale of the cryptocurrency produces a separate taxable result.

For foreign owners, crypto mining tax in Russia does not differ solely because of the company’s ownership structure. Foreign investors generally need to operate through an eligible Russian legal entity included in the official miners' register. A foreign legal entity cannot itself be included under the current registration framework established by Federal Law No. 259-FZ.

How cryptocurrency mining tax in Russia is calculated

The taxation of cryptocurrency mining in Russia is governed by Article 282.3 of the Russian Tax Code. The principal rules can be summarized in four areas.

25% corporate profit tax

Mined cryptocurrency is treated as non-operating income. The rules for corporate profit tax on crypto mining apply equally to Russian companies with domestic and foreign shareholders.

Separate tax base

Income and expenses from digital currency operations are calculated separately from the company’s general corporate profit tax base.

General taxation system

Companies issuing and subsequently selling digital currency cannot use special tax regimes such as the simplified taxation system.

VAT treatment

Mining and the sale of digital currency are not subject to VAT. Hosting, equipment rental and other related services require a separate VAT assessment.

The Russian Federal Tax Service guidance on mining explains the principal tax and valuation rules.

When mining income is recognized and valued

Tax on cryptocurrency mining income arises when the company obtains the right to dispose of the cryptocurrency. For continuous mining or pool rewards credited several times a day, income is determined daily rather than for every individual accrual.

The company uses the closing price calculated by a qualifying foreign trading venue. If several qualifying venues publish quotations for the same cryptocurrency, the taxpayer may select one. A quotation expressed in a foreign currency must then be converted into roubles using the applicable exchange rate on the income recognition date.

The selected quotation source and calculation method should be documented and applied consistently. Digital currency is not subject to current tax revaluation while the company continues to hold it.

Tax treatment of mined cryptocurrency when it is sold

Selling or otherwise disposing of mined cryptocurrency produces a separate taxable result. The company calculates it using the disposal proceeds, the tax value recognized when the cryptocurrency was mined and eligible selling costs. This does not mean that the same income is taxed twice.

The actual sale price is used if it remains within the statutory market-price range. If it is more than 20% below the relevant market quotation, the tax calculation may need to be adjusted. The tax accounting policy should also state whether the cost of disposed cryptocurrency is determined using FIFO or the unit-cost method.

Deductible crypto mining expenses and supporting documents

Mining costs are treated as indirect expenses for corporate profit tax purposes. Deductible crypto mining expenses must have a business purpose, relate to income-generating activity and be supported by appropriate evidence.

When reviewing mining expenses for corporate profit tax purposes, an internal register alone is insufficient. If infrastructure supports mining and other activities, the company should also document how shared costs are allocated.

Registration, reporting and management control

A Russian legal entity may start mining after inclusion in the miners' register. It must electronically report the cryptocurrency received and relevant identification addresses by the 20th day of the following month.

This differs from the quarterly reporting required from mining infrastructure operators. The deadline is confirmed in the Federal Tax Service guidance on mining reports.

For foreign owners and CFOs, tax compliance should form part of a broader management control process. Before mining begins, they should confirm that the operating entity is eligible for registration.

Once operations start, management should verify that:

pool data, wallet transactions and recognized income can be reconciled;
the quotation source and valuation method are documented;
mining costs are separately identifiable and supported;
monthly filings are submitted on time;
headquarters can reconcile operational results with the Russian tax calculation.

This provides foreign management with a clearer view of the company’s taxable income, operating costs and reporting obligations.

How Outsourcing Solutions supports mining companies

Outsourcing Solutions provides accounting and tax support for an international cryptocurrency mining business in Russia operating through a Russian legal entity. The company can help record mining income and expenses, reconcile pool and wallet data, prepare valuation registers and review supporting documents. It can also separate mining costs from other activities, monitor the completeness of reporting information and prepare structured data for foreign headquarters.

Cryptocurrency mining tax in Russia requires a reliable connection between operational data, tax calculations and supporting records. Outsourcing Solutions can help foreign-owned companies establish this process and maintain the information required for Russian tax compliance.

The applicable tax treatment should be reviewed in light of the company’s legal structure, contracts and operating model.

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