Cases from Our Practice
Cases from Our Practice
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CASE
PROBLEM
SOLUTION
RESULT
Assisting a Mining Company with Tax Planning
The company operated a data center for miners but faced the risk of high taxes and difficulties working with banks.
CryptAdvisor's lawyers analyzed the tax burden and proposed an optimal structure. They transitioned the company to a tax regime that allowed for VAT reduction. Contracts with data center clients were developed, considering new legislative requirements. An AML Policy was created and implemented, along with explanations for banks regarding the legality of the activities.
The company reduced tax payments by 30%, simplified interactions with banks, and attracted new clients thanks to a transparent legal structure.
Utilizing Hashrate in Transactions Between a Russian LLC and a Foreign Company
Due to legal restrictions, a foreign company couldn't directly engage in mining in Russia. However, it imported mining equipment into the country, with ownership officially confirmed. A legal model for conducting mining activities indirectly was needed.
Our legal team assisted in establishing an LLC in Russia and registering it in the miners' registry. A custodial agreement was developed, granting partial use of the equipment. The agreement stipulated that a portion of the hashrate remains with the LLC as compensation for technical maintenance, space rental, and electricity. Conditions for equipment return in case of project termination were also outlined. All settlements were conducted in hashrate through a pool. A tax analysis was conducted: the LLC accounts for income in cryptocurrency, while the foreign company avoids paying taxes in Russia.
The company minimized tax and legal risks by registering a legal entity under Russian law and inclusion in the miners' registry. The proposed operational model was recognized as legal and safe from a tax legislation perspective.
Legalization of a 5 MW Mining Farm
The company owned a large mining farm using over 1200 ASIC devices. The business was conducted without formal legal status, which created significant risks — from power shutdowns to fines and tax authority blocks. The client needed to build a business on legal grounds to avoid sanctions and scale the project.
1. Legal Structure:
- The company was transitioned to the general taxation system (OСНO).
- The following NACE codes were selected: 63.11 — Data processing, 62.09 — IT services, 64.99 — Financial services
- Obtained technical connection for 5 MW.
- Signed an electricity supply contract at industrial tariffs.
- Installed a consumption monitoring system.
- Registered the company in the operator registry in accordance with Federal Law No. 259.
- Prepared the documentation package confirming the infrastructure.
- Profit tax — 25%, with consideration for depreciation and expenses.
- VAT on the sale of digital assets — 0% (per paragraph 3.1, Article 149 of the Tax Code of the Russian Federation).
- Accounting for 1200 ASIC devices as fixed assets with depreciation according to the Russian Classification of Fixed Assets (OKOF).
- A structure was created with a subsidiary company in the UAE (0% tax).
- Cryptocurrency was sold through an international platform.
- Revenues are repatriated to Russia via currency contracts.
- Currency control requirements were met.
The mining farm was legalized and operates within the law.
Risks of fines, shutdowns, and audits have been eliminated.
The client has a transparent business model with the possibility of scaling and legally withdrawing income.
Risks of fines, shutdowns, and audits have been eliminated.
The client has a transparent business model with the possibility of scaling and legally withdrawing income.
Bank Account Unblocking
A client’s bank account was blocked due to suspicious cryptocurrency-related transactions (P2P transfers), with the bank citing Federal Law No. 115-FZ. The client had been selling USDT on Binance P2P. Buyers transferred funds in rubles to the client’s bank card. The transactions appeared as follows:
• multiple incoming transfers from different bank cards,
• followed by withdrawals of these funds,
• no visible salary or other legitimate sources of income.
The bank blocked the account and requested an explanation of the funds’ origin and the economic purpose of the transactions.
• multiple incoming transfers from different bank cards,
• followed by withdrawals of these funds,
• no visible salary or other legitimate sources of income.
The bank blocked the account and requested an explanation of the funds’ origin and the economic purpose of the transactions.
CryptAdvisor lawyers analyzed the transactions and prepared a justification for their legality.
They provided the bank with income documents and a tax declaration, initiated the account rehabilitation procedure, and held negotiations with the bank.
To prevent future account blocks, they also developed a strategy for working with cryptocurrency.
They provided the bank with income documents and a tax declaration, initiated the account rehabilitation procedure, and held negotiations with the bank.
To prevent future account blocks, they also developed a strategy for working with cryptocurrency.
We helped the client go through the rehabilitation procedure with the bank, including:
• Collecting the necessary evidence to prove the legitimacy of the funds (Binance P2P deal screenshots, correspondence, transaction history).
• Communicating with bank employees (account manager, compliance officer) during the rehabilitation process and preparing written explanations of the client’s activities.
• Engaging with the cryptocurrency buyer to obtain proof of the origin of their funds (personal income tax forms, etc.).
• Confirming the client’s tax status (self-employed/sole proprietor).
As a result, the client’s risk level was reassessed and the account was unblocked.
• Collecting the necessary evidence to prove the legitimacy of the funds (Binance P2P deal screenshots, correspondence, transaction history).
• Communicating with bank employees (account manager, compliance officer) during the rehabilitation process and preparing written explanations of the client’s activities.
• Engaging with the cryptocurrency buyer to obtain proof of the origin of their funds (personal income tax forms, etc.).
• Confirming the client’s tax status (self-employed/sole proprietor).
As a result, the client’s risk level was reassessed and the account was unblocked.
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CryptAdvisor
About Us
We are a team of specialists in civil, information, and tax law, specializing in services related to mining and digital financial assets.
Our team comprises highly qualified and experienced professionals who are not afraid of complex tasks and successfully support projects in the digital sphere.
Our goal is not just to solve legal issues but to become your reliable partner on the path to success.
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Phone: +7 964 3989978
Email: info@cryptadvisor.ru
Address: St. Petersburg, Lev Tolstoy St., 1–3
Metro: Petrogradskaya
Email: info@cryptadvisor.ru
Address: St. Petersburg, Lev Tolstoy St., 1–3
Metro: Petrogradskaya
