The Ministry of Finance of the Russian Federation (the "Ministry") has indicated that gift certificates do not generate taxable income at the time of sale, because they are treated as the prepayment of goods and not as goods themselves.
Specifically, the Ministry states that taxable income from the sale of gift certificates is generated when a customer exchanges the gift certificate for goods. If the gift certificate remains unclaimed, the money received from the "sale" will be included in the profit tax base.
In addition, the Ministry indicates that it is necessary (i) to use a cash register machine when selling a gift certificate; and (ii) to present a sales receipt to the purchaser. However, the Ministry does not clarify whether a sales receipt needs to be issued when exchanging a gift certificate for goods.
[Letter No. 03-03-06/1/268 of the Ministry of Finance of the Russian Federation, dated 25 April 2011]