Tax classification of the ruble-based stablecoin А7А5 and the mechanism for documenting cross-border transactions

The subject of the study is the tax consequences, documentary confirmation mechanisms, and compliance risks of using the ruble-based stablecoin (A7A5) in cross-border transactions between Russian sellers and Chinese counterparties amid sanctions and the lack of special tax regulation for digital currencies in Russia. The analysis covers: qualification of the stablecoin in tax and currency legislation; problems of determining income recognition when tokens are credited to an operator's wallet; lack of an official exchange rate for revaluation; impossibility of confirming expenses with non-resident crypto exchange statements; and risks of losing zero VAT rate and underestimating the insurance premium base. The study also examines compliance risks (AML/CFT, currency control, sanctions), a comparative analysis of Kazakhstan's (AIFC) and Belarus' (PVT) approaches, and a legalization model equating stablecoins to non-cash rubles under an experimental legal regime. The methodology includes comparative legal analysis of regulations of Russia, Kazakhstan, Belarus, and China, formal legal method, judicial practice analysis, and legal modeling. The scientific novelty lies in the comprehensive justification of a ruble-denominated stablecoin issued as a digital financial asset (DFA) being treated as non-cash ruble funds, applying fiscal neutrality where payment form does not affect tax consequences. For the first time, a mechanism is proposed for documenting cross-border transactions using DFA operator statements as primary accounting documents. Specific amendments to the Tax Code (Articles 38, 164, 252, 271, 421) and the Federal Law “On Accounting” are formulated, along with an experimental legal regime for ruble-stablecoin settlements between Russian sellers and Chinese counterparties.