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Mining, pools, hashrate

Administration of the mining industry was transferred to Russia’s FNS (Federal Tax Service) — making tax expertise a core capability for the sector. Twenty years of tax-dispute practice, including wins before the Economic and Administrative benches of the Supreme Court, applies directly here: the language, logic and procedures of the tax authorities are known from the inside.

Core of the practice

Disputes with the FNS

Defence of miners and infrastructure operators in audits and assessments: challenging the tax base on mined currency, the timing of income recognition, and activity qualification. Pre-trial settlement and court representation.

Accounting

Taxation of mined currency

Setting up tax accounting for mining: valuation of mined digital currency, recognition of income and expenses — electricity, equipment, hosting — and choosing an optimal structure from sole trader to a group of companies.

Reference

Reference tax experience

  • Wins before the Economic and Administrative benches of the Supreme Court of Russia
  • Tax reconstruction calculations that reduced claims by billions of roubles
  • Dispute support that released top managers from multi-billion subsidiary liability
  • Dozens of tax audits settled pre-trial
Questions

Common questions

What taxes does a miner pay in Russia?
Income in the form of mined digital currency is taxed under general rules: personal income tax for individuals and corporate profit tax for organisations, with income recognised at the market value of what was mined. Mining costs — electricity, equipment — are deductible when accounting is set up correctly.
When does a miner’s income arise — on mining or on sale?
The legislative model provides for income recognition already on receipt of digital currency, with later accounting for the financial result on disposal. Practical details — valuation rate, documentation — are the source of most disputes with the FNS.
Must a miner register in the register?
Yes, mining activity above established consumption thresholds requires inclusion in the miners’ register administered by the FNS. Work outside the register creates risks from a ban on activity to tax assessments under the worst-case scenario for the miner.
What to do in a tax audit of mining activity?
Do not cede the initiative: correctly framed explanations, a counter-calculation of the base and a pre-trial position resolve most disputes before court. Experience shows that quality pre-trial work reduces claims many times over.
How does the FNS determine the value of mined currency?
At market quotes at the time of receipt — but the choice of quote source and the conversion into roubles leave room for dispute. Valuation methodology co-developed by the practice — guidance for an appraisers’ SRO — is an argument in such disputes.
Can electricity and equipment costs be deducted?
Yes, with documentary support and a correct accounting policy. A typical error is bulk accounting without a link to mining output, which tax authorities disallow; proper accounting closes that vulnerability.
What risks does a hosting provider and mining hotel face?
Through recharacterisation: tax authorities may treat an infrastructure operator as a de facto miner with all tax consequences. The contractual structure and operating model must exclude that reading — specialised legal programmes have been developed for mining hotels.
Does management face subsidiary liability for a mining company’s tax debts?
The risk exists where assessments escalate into insolvency. Practice defending top managers — including release from multi-billion subsidiary liability — shows that a timely procedural strategy works.
The pool is registered abroad — where do taxes arise?
The place of taxation is determined by the miner’s residence and the actual place of activity, not by the pool’s jurisdiction. A foreign pool does not remove income from Russian taxation, but it affects documentation.
Where to start legalising a mining business?
Start with an audit: matching actual activity against register and tax requirements, quantifying historical risks, a legalisation plan. Then — registration, accounting policy, and where needed work with accumulated history.
Next

Mining’s place in the new regulation is covered on the page of Law No. 282-FZ. Major dispute representation is led by the agency team Parallax.

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