Annotation

The current Russian legislation contains a contradiction in providing judicial protection guarantees only to cryptocurrency holders who have notified the authorities of their ownership. This inconsistency arises because the tax legislation does not establish a procedure for Russian residents to report to the tax authorities the possession of or transactions involving digital currency, unless they are engaged in mining activities. Granting the right to judicial protection to all cryptocurrency holders, regardless of notification, would allow transactions involving digital currencies made without the mandatory reporting of their possession or transfer to be qualified as tax evasion violating public order, thereby serving the fiscal interests of the state.