Blockchain technology in tax law theory and tax administration

Cover Page

Cite item


The article is devoted to the problems of improving the tax legislation of Russia at the stage of active implementation of blockchain technology, which is characterized by contradictory trends in the legal regulation of digital technologies. The relevance of the study of application of blockchain in tax relations is due to the need to assess the tax consequences of transactions using digital financial assets, as well as emergence of new directions for improving tax control based on blockchain technology. The purpose of the study is to analyze the provisions of Russian and foreign tax legislation, as well as doctrinal sources on improving legal regulation of tax relations in regard to blockchain technology. The study shows efficacy of the blockchain analysis for the purposes of tax and legal regulation carried out by developing concepts related to applying such technological solution as a tool in conducting cryptocurrency transactions. The theoretical significance of the study lies in the author’s definition of the concept of blockchain technology for tax purposes, as well as in proving the value of legal regulation of tax relations applying blockchain. The practical implication is connected with voicing the need to develop legal regulation of applying blockchain technology when creating a system of transactional (automatic) taxation and levying the so-called “smart taxes” while fulfilling tax obligations in the context of introducing a goods traceability mechanism. This will also contribute to minimizing tax reporting. The research methodology are general and private scientific methods of knowledge: formal-legal, analysis, comparative-legal, and forecasting and modeling. The last two are often applied in tax law in light of digitalization and globalization.

About the authors

Olga I. Lyutova

National Research University Higher School of Economics (NRU HSE)

Author for correspondence.
ORCID iD: 0000-0002-6603-8859

Candidate of Legal Sciences, leading researcher at the Institute of State and Municipal Administration

20 Myasnitskaya str., Moscow, 101000, Russian Federation

Irina D. Fialkovskaya

National Research Nizhny Novgorod State University named after N.I. Lobachevsky


Candidate of Legal Sciences, Associate Professor of the Department of Administrative and Financial Law

23 Gagarina pr., Nizhny Novgorod, 603022, Russian Federation


  1. Abramov, V., Popov, N., Istomin, E., Sokolov, A., Popova, A. & Levina, A. (2020) Blockchain and big data technologies within geo-information support for arctic projects. Proceedings of the 33rd International Business Information Management Association Conference, IBIMA 2019: Education Excellence and Innovation Management through Vision. Granada, Spain. doi: 10.1088/1757-899X/940/1/012003
  2. Barakina, E.Y. (2018) The concept of “blockchain technology” and its application in the national payment system of the Russian Federation: issues of legal regulation. Banking law. (1), 53-58 (in Russian)
  3. Demin, A.V. (2017) Dispositivity and taxation: commentary on tax administration legislation and practices. ConsultantPlus. (in Russian).
  4. Filin, S.A. & Tchaikovskaya, L.A. (2020) Taxes in the digital economy and cyberphysical technologies. International accounting. (8), 940-958. (in Russian).
  5. Gracheva, E.Yu. (ed.) (2020) Current problems of financial law in the conditions of digitalization of the economy: monograph. Moscow, Prospect Publ. (in Russian).
  6. Hwan, L.B. (2017) Administrative discretion in tax legal relations (based on the materials of the Republic of Uzbekistan). Public Law Yearbook 2017: Discretion and Evaluation Concepts in Administrative Law, pp. 161-189 (in Russian)
  7. Khavanova, I.A. (2017) Tax jurisdiction: possible and deferred risks. Journal of Russian Law. (12), 81-91 (in Russian)
  8. Khavanova, I.A. (2020) Smart contracts: the phenomenon of techno-legal regulation and taxes. Financial law. (3), 36-38 (in Russian).
  9. Kucheryavenko, N.P. (2017) Features of discretion in tax and legal regulation. In: Public Law Yearbook 2017: Discretion and evaluation concepts in administrative law. Moscow, Infotropik Media Publ. pp. 45-63. (in Russian).
  10. Lyutova, O.I. (2020) Operators of electronic platforms as participants in tax relations of the digital era (using the example of tax on professional income). Pravoprimenenie. (4), 56-67. (in Russian).
  11. Mamonova, I.V. (2018) Trends and prospects of tax administration in modern conditions. Taxes. (1), 37-41. (in Russian).
  12. Migacheva, E.V. (2018) Tax control in the context of the development of the digital economy. Financial law. (8), 21-25 (in Russian).
  13. Nam, K.V. (2019) Legal problems related to the use of blockchain. Judge. (2), 24-27 (in Russian).
  14. Rozhkova, M.A. (2018) Internet law: a collection of papers. Moscow, Statute Publ. (in Russian).
  15. Shishkin, R.M. (2019) Tax benefit in business fragmentation: the position of tax authorities and courts. Moscow, Editorial Board of Rossiyskaya Gazeta Publ. Issue 3. (in Russian).
  16. Sinyagovskaya, E.S. & Kuroptev, N.B. (2020) Problems of introduction of traceability system of goods in EAEU. Innovation Technology Newsletter. 3 (915), 33-38 (in Russian).
  17. Swan, М. (2015) Blockchain: Blueprint for a New Economy. Boston, O’Reilly Media.
  18. Tabernakulov, A. & Kuifmann, Y. (2019) Blockchain in practice. Moscow, Alpina Pablisher. (in Russian).
  19. Talapina, E.V. (2019) Blockchain in public administration: legal prospects and risks. Laws of Russia: experience, analysis, practice. (5), 77-82 (in Russian).
  20. Tapscott, D. & Tapscott, A. (2016) Blockchain Revolution: How the Technology Behind Bitcoin is Changing Money, Business, and the World. London, Portfolio.
  21. Tapskott, D. (2018) Blockchain technology: what drives the financial revolution today. Moscow, Eksmo Publ. (in Russian).
  22. Tikhonova, A.V. (2020) Cryptocurrency and blockchain: scope of application in Russian tax law. Taxes and taxation. (4), 1-9 (in Russian).
  23. Tregubov, A.N. (2019) Establishment of a traceability system as a response to smuggling of goods. Сustoms affairs. (3), 16-18 (in Russian).
  24. Tsindeliani, I.A. (ed.). (2019) Financial law in the development of the digital economy: monograph. Moscow, Prospect Publ. (in Russian).
  25. Varnavsky, A.V., Buryakova, A.O. & Sebechenko, E.V. (2020) Blockchain in the service of the state: monograph. Moscow, KNORUS Publ. (in Russian).
  26. Viña, P. (2018) The era of cryptocurrencies. How Bitcoin and blockchain are changing the world economic order. Moscow: Mann, Ivanov and Ferber Publ. (in Russian).
  27. Xu, Y. & Huang, Y. (2020) Segment blockchain: a size reduced storage mechanism for blockchain. International Journal of Energy Sector Management. (8), 17434-17441.
  28. Yankovsky, R.M. (2018) Problems of legal regulation of cryptocurrencies. Business law. Business and Law application. (1), 45-51. (in Russian).
  29. Zhuravlev, A., Brisov, Yu., Yankovsky, R. & Levashenko, A. (2020) The evolution of cryptoeconomics and recent trends in decentralized finance. Bank Review. (10), 32-35. (in Russian).

Copyright (c) 2021 Lyutova O.I., Fialkovskaya I.D.

Creative Commons License
This work is licensed under a Creative Commons Attribution 4.0 International License.

This website uses cookies

You consent to our cookies if you continue to use our website.

About Cookies