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MINISTRY OF FINANCE OF RUSSIA

FEDERAL TAX SERVICE
OF RUSSIA
DEPUTY CHIEF
23 Neglinnaya Street, Moscow, 127381
Ph.: 913-00-09; Fax: 913-00-05
www.nalog.ru
07.14.2016

To: Pakhanov D.I.
dmitriyy-paha@rambler.ru

No.OA-3-17/3250@

Inquiry No.

Dear Dmitriy Igorevich!
The Federal Tax Service, after reviewing your internet-inquiry dated 05.24.2016 (ref.
No.013769/ZG), is hereby informing you, that the absence of specific documents necessary for the
assessment of the conditions of the contractual obligations between the parties and related
circumstances, does not allow for complete answers to the questions stated in the inquiry.
However, we are able to provide the following information.
In accordance with the sub-paragraph “b” of Paragraph 9 of Part 1 of the Article 1 of the
Federal Law dated 12.10.2003 No.173-FZ “On currency regulation and currency control” (further in
the text – Law No.173-FZ), the acts of acquisition by a resident from a non-resident and alienation by
a resident to a non-resident of currency valuables, currency of the Russian Federation and domestic
securities on lawful terms, and the use of currency valuables, currency of the Russian Federation and
domestic securities as a means of payment are deemed currency transactions.
Consequently, the transactions of purchase and sale of cryptocurrency (virtual currency)
between residents and non-residents, with the utilization of currency valuables and (or) currency of the
Russian Federation, are, in fact, currency transactions.
In accordance with Part 7 of Article 12 of the Law No.173-FZ, individuals-residents are
required to report to the tax authorities of their local registration on the movements of funds in the
accounts (deposits) held at the banks outside of the territory of the Russian Federation, in the order
established by the Resolution of the Government of the Russian Federation “The procedure of
reporting by individuals-residents to the tax authorities on the movement of funds in the accounts
(deposits) held at banks outside of the territory of the Russian Federation.”
Concurrently, Article 12 of Law No.173-FZ lists a limited number of currency transactions,
which individuals-residents may perform through the accounts (deposits) at banks located outside of
the territory of the Russian Federation.

Currency transactions that are prohibited by Law No.173-FZ from being performed through the
accounts (deposits) at banks located outside of the territory of the Russian Federation must be
performed through accounts at authorized banks.
Thus, in accordance with the norms of the currency legislation of the Russian Federation,
individuals-residents are required to submit to the tax authorities of their local registration the reports
on all currency transactions performed through the accounts (deposits) held at the banks outside of the
territory of the Russian Federation.
Please note, that the explanations on the legislation on currency regulation and currency
control are also available on the main page of the official website of the Federal Tax Service of Russia
(www.nalog.ru) in the “Frequently Asked Questions” section.
This explanation (letter) is not a legal act, does not entail changes to the legal regulation of
currency relations, does not contain provisions that entail legal consequences for an unspecified
number of persons, is intended for informational purposes, and does not prevent residents (nonresidents) from be guided by the currency legislation of the Russian Federation within the meaning
different from the provisions of this letter.

Acting Class 2 State Civil Service Advisor
of the Russian Federation

Clerk: Lyubvin S.Y.
(495) 913-00-00 (1234)

[ Signed ]

A.L. Overchuk