On August 4, 2026, the President of the Russian Federation signed Federal Law No. 292-FZ (hereinafter referred to as the “Law”), which, among other things, introduces a new tax regime for income and expenses related to transactions involving debt-based financial instruments.
The concept and characteristics of debt-based digital financial assets were established as early as December 2025 (we discussed them in detail in a previous publication).
In the broadest sense, debt-based digital financial assets are economically analogous to traditional bonds. At the same time, unlike bonds, they were previously subject to a special tax regime.
For corporate income tax purposes, income and expenses from transactions involving any digital rights were included in a separate tax base (along with non-tradable securities and derivative financial instruments). For this reason, issuers of debt-based digital financial assets could not deduct expenses related to payments to their holders or use these expenses to reduce income from core operations within the general tax base. This made debt-based digital financial assets a less attractive instrument for raising capital compared to traditional financial market instruments.
The law introduces a new paragraph 2.1 into Article 282.2 of the Tax Code of the Russian Federation, pursuant to which:
- a taxpayer’s income and expenses in the form of periodic payments on debt securities (not related to their repayment) are included in the total tax base;
- the procedure for accounting for and recognizing such income and expenses is determined by the rules for accounting for and recognizing interest on debt obligations arising from loan agreements and securities;
- the new rules apply to legal relationships arising on or after January 1, 2026 (i.e., including the current tax period).
The new rules primarily allow for the optimization of taxation for issuers of debt securities. Please note that they apply only to “coupon” payments on debt securities, while expenses related to the payment of the par value of debt securities continue to be included in a separate tax base.
It should be noted that a similar provision was included in Bill No. 1222105-8, which has so far been adopted by the State Duma only in its first reading. This bill also provides for a set of other amendments to the Tax Code of the Russian Federation concerning digital currencies and digital rights—in particular, the inclusion in the general tax base of income and expenses from transactions involving the redemption of debt-based digital financial assets traded on organized markets.
It is noteworthy that during the initial review stage, the bill did not address issues related to the digital asset market at all—the provision on the taxation of debt-based digital financial assets was added during the second reading.
