Mikhail Uspenskiy

Home / Jurisdictions

International structuring

Choosing a jurisdiction and supporting the creation of foreign structures for crypto projects: licensing, operating model, tax consequences for Russian beneficial owners, including controlled foreign company rules. The practice covers the UAE, Kyrgyzstan, Armenia, Georgia and other friendly jurisdictions.

Selection

Matching a jurisdiction to the task

A jurisdiction is chosen by function, not fashion: exchange activity, prop trading, infrastructure, settlement contour. Comparative analysis across regulation, banking, tax and compatibility with the Russian perimeter.

Jurisdictions

Focus jurisdictions

United Arab Emirates

Mainland and free-zone regimes, virtual-asset licensing, banking and the tax model for Russian beneficial owners.

Open jurisdiction

Kyrgyzstan

Sector licensing for virtual assets, operating models and settlement tasks within the EAEU perimeter.

Open jurisdiction

Armenia

Organisational forms, preferential regimes for technology companies, banking and tax consequences for Russian beneficiaries.

Open jurisdiction

Georgia

Virtual-asset service-provider regulation, preferential zones, tax model and compatibility with the Russian perimeter.

Open jurisdiction
CFC

CFCs and the Russian perimeter

Assessing consequences for Russian beneficial owners: controlled foreign company rules, notifications, and compatibility of a foreign structure with Russian activity. Related structuring work — on the page Digital project structuring; sanctions aspects — under Compliance and sanctions risk.

Questions

Common questions

How to choose a jurisdiction for a crypto project?
Start from the structure’s function: what is optimal for an exchange business may not suit prop trading or an infrastructure project. The choice is the result of comparative analysis of regulation, banking, tax burden and practical executability.
Must a Russian beneficial owner report a foreign company?
As a rule, yes: controlled foreign company (CFC) rules provide for notifications and, under certain conditions, taxation of CFC profits. Ignoring this block is the most expensive mistake when going abroad.
What does a “friendly jurisdiction” mean and why does it matter?
Whether a jurisdiction is on the friendly list affects the applicability of a number of Russian restrictions and the practical operation of settlements. It is one selection filter, but not the only one.
Can a foreign structure be combined with a Russian business?
Yes, with a correct separation of functions and cash flows. The “Russian perimeter + foreign structure” link is most often precisely the subject of design.
Do you support creating a structure end to end?
Yes: from choosing a jurisdiction and designing the structure to engaging local counsel, registrars and banks.
Next

Project design for digital structures — structuring; sanctions and banking compliance — compliance practice. Complex mandates with Parallax.

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