VAT/GST Treatment of Digital Assets

Regulator-Grade Guidance Document

Date: June 2026 Domain: Digital Asset Taxation Section: VAT/GST Treatment Audience: Tax authorities, indirect-tax policymakers, VASP compliance teams

1. The Core Question: Is Crypto a Currency or a Good?

The VAT/GST treatment of digital assets hinges on a single classification question: does a cryptocurrency function as money (and therefore fall outside the scope of VAT/GST or qualify for a financial services exemption), or does it constitute a good or service (and therefore attract standard-rate VAT/GST on every transfer)?

If crypto is treated as a good, every purchase of cryptocurrency with fiat currency triggers VAT/GST. Every subsequent use of that cryptocurrency to buy goods or services triggers VAT/GST again -- on both the crypto transfer and the underlying supply. This creates double taxation: the consumer bears VAT/GST twice compared to a fiat transaction. This is not a theoretical concern; it was the actual situation in

Australia before 2017 and in most EU member states before the 2015 Hedqvist ruling.

The international consensus has converged across all 19 jurisdictions surveyed, though through different mechanisms:

• EU: The CJEU ruled in Hedqvist (2015) that Bitcoin is analogous to a currency for VAT purposes and exchange services are exempt financial transactions. The ruling binds all 27 member states, including
  France,
  Germany, and
  Portugal.
• Australia: Parliament legislated in 2017 to treat digital currency equivalently to money for GST purposes, eliminating double taxation.
• Singapore: IRAS amended the GST Act effective 1 January 2020 to exempt digital payment token (DPT) exchanges from GST.
• UAE: Cabinet Decision No. 100 of 2024 retroactively exempted virtual asset transfers, conversions, and custody from VAT back to 1 January 2018.
• Japan: The Consumption Tax Act was amended effective 1 July 2017 to exempt crypto asset transfers from the 10% consumption tax.

The classification problem is not fully resolved. Tokens that do not function as payment instruments -- including NFTs, utility tokens, and certain DeFi governance tokens -- may not benefit from the exemptions designed for payment-type crypto. This creates a regulatory gap that jurisdictions are only beginning to address. A second group of jurisdictions --

the United States,

India,

Nigeria,

Brazil -- either has no VAT/GST at all or imposes indirect tax only on intermediary service fees rather than on the token transfer itself.

2. The Hedqvist Precedent (CJEU C-264/14)

Facts

David Hedqvist intended to operate a Bitcoin exchange service in Sweden, exchanging Bitcoin for Swedish kronor and vice versa. Before commencing operations, he sought a ruling from the Swedish Revenue Law Commission (Skatterattsnamnden) on the VAT treatment. The Swedish Tax Agency (Skatteverket) challenged the ruling, and the case was referred to the CJEU for a preliminary ruling.

Ruling (22 October 2015, Fifth Chamber)

The CJEU held:

1. Supply of services for consideration: Exchanging Bitcoin for fiat currency constitutes a supply of services for consideration under Article 2(1)(c) of the VAT Directive (2006/112/EC). The consideration is the margin between buy and sell prices.

2. Exempt financial transaction: The exchange service falls within the exemption under Article 135(1)(e) of the VAT Directive, which covers "transactions, including negotiation, concerning currency, bank notes and coins used as legal tender." Bitcoin functions as a contractual means of payment analogous to legal tender.

3. Not a supply of goods: Bitcoin has no purpose other than as a means of payment and is accepted as such by certain operators. It is therefore not a tangible good.

Implications for Regulators

The Hedqvist ruling has become the de facto global template for VAT/GST treatment of crypto exchange services. Its influence extends well beyond the EU:

• All EU member states are bound by the ruling and must exempt crypto-to-fiat exchange services from VAT.
  France applies it directly;
  Germany adopted it through the BMF letter of 27 February 2018;
  Portugal applies it through the AT's reliance on the EU jurisprudence.
• UK HMRC adopted the Hedqvist reasoning in Revenue & Customs Brief 09/14 and the Cryptoassets Manual (CRYPTO45000), despite Brexit.
• Switzerland applies an analogous exemption, treating crypto exchange as equivalent to foreign exchange for VAT purposes, though it is not bound by CJEU rulings.
• UAE,
  Japan,
  Singapore, and
  Australia reached the same policy outcome through domestic legislation or administrative guidance rather than judicial precedent.

Limitation: The Hedqvist ruling addressed only Bitcoin-to-fiat exchange. It did not address mining, staking, NFTs, DeFi services, or utility tokens. The extension to crypto-to-crypto exchanges is applied by analogy in most member states but has not been confirmed by the CJEU.

Source: EUR-Lex -- Case C-264/14 Skatteverket v David Hedqvist | Norton Rose Fulbright -- ECJ rules on Bitcoin VAT

3. Activity-by-Activity VAT/GST Treatment

3.1 Crypto-to-Fiat Exchange

This is the activity with the highest degree of international consensus.

Regulator takeaway: There is near-universal consensus that the crypto-to-fiat token transfer should not bear standard-rate VAT/GST -- either as an exempt financial service, by treating digital currency equivalently to money, or because the jurisdiction has no VAT at all. The exceptions are

Nigeria (which applies 7.5% VAT to exchange fees, not the token) and the

UAE (5% on mining, but not on the exchange itself). No major jurisdiction currently imposes standard-rate VAT/GST on the underlying crypto-to-fiat exchange.

3.2 Crypto-to-Crypto Exchange

Regulator takeaway: Crypto-to-crypto swaps generally receive the same exempt or disregarded treatment as crypto-to-fiat. However, the legal basis is sometimes uncertain (particularly in the EU, where the CJEU has not ruled directly on this).

Germany and

Switzerland are notable for expressly confirming that crypto-to-crypto exchange is VAT-exempt, not merely crypto-to-fiat.

3.3 Mining Services

Mining presents a unique VAT/GST challenge: the miner performs computational work, but there is typically no identifiable customer for the services. The block reward comes from the protocol, not from a counterparty.

Critical divergence: The

UAE stands alone among major jurisdictions in explicitly subjecting mining to VAT (5%) under VATP039 (January 2025). Most jurisdictions treat solo mining as outside the scope of VAT because no identifiable customer exists. However, pool mining and mining-as-a-service (where a miner performs services for a customer in exchange for fees) may attract VAT in jurisdictions that otherwise exempt solo mining -- this is the express position in

France,

Germany, and

Switzerland.

3.4 Staking Services

Staking shares mining's fundamental challenge: are staking rewards consideration for a service, or are they protocol-generated returns with no identifiable customer?

Regulator takeaway: Staking presents a spectrum. Passive staking (delegating tokens) is more akin to earning interest and is likely outside the scope of VAT/GST. Active staking (operating a validator node) may constitute a service provision, particularly when staking-as-a-service is offered to third-party customers for a fee.

3.5 NFT Sales

NFTs present the most significant unresolved VAT/GST question in the digital assets space. Unlike fungible payment tokens, NFTs are unique, non-fungible digital items and generally fall outside the "currency" or "payment instrument" exemptions.

EU VAT Committee Working Paper No. 1060 (21 March 2023): The Committee's preliminary view is that the provision of an NFT is generally a supply of services (not goods), potentially classifiable as an "electronically supplied service" under the VAT Directive. If the NFT represents rights to a physical good, the VAT treatment follows the underlying good. The Working Paper is non-binding and intended to stimulate discussion toward a common position across member states.

Source: EY -- EU VAT Committee publishes working paper on NFTs

3.6 DeFi Services

DeFi activities (decentralized exchange swaps, liquidity provision, lending, yield farming) present the frontier of VAT/GST uncertainty. No major jurisdiction has published comprehensive DeFi-specific VAT/GST guidance as of June 2026.

General principles that may apply:

• Token swaps on DEXs: If both tokens are payment-type tokens, the swap may qualify for the same exempt treatment as centralized crypto-to-crypto exchanges. If one or both tokens are utility or governance tokens, the exemption may not apply.
• Liquidity provision: Depositing tokens into a pool and receiving LP tokens may or may not constitute a taxable supply, depending on whether the depositor is providing a "service" to the pool.
• Lending: Interest earned from crypto lending may be treated as consideration for an exempt financial service (similar to conventional lending), or as a standard-rate taxable service, depending on the jurisdiction.
• Yield farming rewards: Protocol-generated rewards face the same "no identifiable customer" problem as mining and staking.

Regulator takeaway: DeFi is the most significant gap in current VAT/GST frameworks. Regulators should prioritize guidance on whether DeFi protocol interactions constitute supplies of services for VAT/GST purposes, and if so, who the supplier and recipient are.

3.7 Custody/Platform Fees

Unlike token transfers, fees charged by exchanges, custodians, and platforms for their services are generally treated as taxable supplies of services subject to standard-rate VAT/GST -- except where a jurisdiction treats exchange-arrangement charges as exempt financial services.

Important distinction in the

UK: HMRC treats exchange-arrangement charges above token value as exempt financial services under Item 5, Schedule 9, Group 5 of the VATA 1994, which is more favorable than many jurisdictions that treat platform fees as standard-rated.

4. Comparative Table (All 19 Jurisdictions)

Aggregate (19 jurisdictions):

• 1 of 19 has no VAT/GST at all (
  United States).
• 8 of 19 expressly exempt or disregard the crypto-to-fiat/crypto-to-crypto token transfer as a financial-type supply or money-equivalent (
  EU,
  France,
  Germany,
  Portugal,
  Switzerland,
  Australia,
  Singapore,
  Japan, plus
  UK and
  South Africa -- exempting all EU members raises the count higher when counted individually).
• 2 of 19 explicitly tax a crypto-specific activity despite the general no-VAT-on-transfer consensus: the
  UAE (5% on mining, VATP039) and
  Nigeria (7.5% on VASP fees).
• 2 of 19 apply no specific VAT/GST classification to crypto, leaving transfers outside the indirect-tax base while taxing intermediary fees:
  India (18% on platform fees only) and
  Brazil (ISS on service fees only).
• 1 of 19 has no published VAT guidance for crypto at all (
  South Korea).

5. Special Issues

5.1 Double Taxation Problem (Pre-GST Reform Australia)

Before 1 July 2017,

Australia provided the clearest illustration of what happens when digital currency is treated as a good rather than money for GST purposes.

The problem: A consumer buying Bitcoin with AUD triggered GST on the Bitcoin purchase (because it was a supply of a good/service). When the consumer then used that Bitcoin to buy a coffee, GST was charged again -- on the coffee. The consumer bore GST twice: once on acquiring the payment instrument and once on the underlying transaction. Fiat currency transactions bore GST only once (on the goods/services).

The solution: The Treasury Laws Amendment (2017 Measures No. 6) Act 2017, enacted 30 October 2017 with retrospective effect from 1 July 2017, amended the A New Tax System (Goods and Services Tax) Act 1999 to:

• Disregard supplies and acquisitions of digital currency for GST purposes (matching the treatment of money)
• Recognize digital currency supplies for GST only when exchanged for money or other digital currency, treating such supplies as input-taxed financial supplies

Definition of digital currency (section 195-1 GST Act): Fungible digital units of value that (i) function as consideration for transactions, (ii) are generally available to the public, (iii) are not denominated in any country's currency, (iv) do not derive their value from another thing, and (v) are not issued by a government body.

Limitation: The definition requires fungibility. NFTs, by definition, are non-fungible and therefore may not qualify for the GST exemption. This gap has not been legislatively addressed.

Sources: Australian Treasury -- GST: removing the double taxation of digital currency | HN Law -- Relief for GST Treatment of Digital Currencies in Australia | Regulation Tomorrow -- Removing the double taxation of digital currency

5.2 Input Tax Credit Recovery

When crypto exchange services or mining services are exempt from VAT/GST (rather than zero-rated or outside the scope entirely), businesses may face restricted input tax credit (ITC) recovery.

The issue: Under most VAT/GST systems, a business making exempt supplies cannot recover the VAT/GST paid on its inputs (office rent, equipment, software licenses, electricity). This creates a hidden cost for crypto service providers.

• EU: Crypto exchanges making exempt supplies under Art. 135(1)(e) are treated as financial service providers for ITC purposes. They cannot recover input VAT on costs attributable to exempt activities. Partial exemption rules apply where the business also makes taxable supplies.
• Australia: Digital currency exchanges making input-taxed financial supplies face reduced ITC entitlements under Division 11 of the GST Act. The 2017 reform treated DCE services as input-taxed (not GST-free), which means DCEs bear irrecoverable GST on their business costs.
• Singapore: DPT transactions are exempt supplies and do not count toward the SGD 1 million GST registration threshold. Businesses making only exempt DPT supplies may not be able to register for GST and therefore cannot recover input GST. Businesses with mixed supplies must apportion input tax.
• UAE: Businesses whose crypto activities are solely VAT-exempt under Cabinet Decision 100/2024 may not need VAT registration, but those with mixed supplies (e.g., mining plus trading) must register and apportion input tax.

Regulator takeaway: The choice between "exempt," "zero-rated," and "outside the scope" has significant consequences for business costs. Zero-rating (maintaining the right to recover input tax) is more favorable to businesses than exemption. Jurisdictions should consider whether the ITC restriction on exempt crypto services creates an unintended competitive disadvantage.

5.3 Cross-Border Digital Services

Crypto services are inherently borderless, creating place-of-supply challenges for VAT/GST.

Key principles from the OECD International VAT/GST Guidelines:

• B2B transactions: The place of supply is the jurisdiction of the business recipient (reverse-charge mechanism applies).
• B2C transactions: The place of supply is the jurisdiction of the consumer (destination principle). This is the approach adopted by the EU for electronically supplied services, requiring non-EU suppliers to register and charge VAT in the consumer's country.

Application to crypto services:

• Exchange platform fees: Where a crypto platform charges fees to consumers in multiple jurisdictions, the destination principle requires the platform to charge VAT/GST at the rate of the consumer's jurisdiction (for B2C supplies). The EU One-Stop Shop (OSS) system simplifies this for EU-based suppliers.
• Imported digital services:
  Nigeria requires foreign providers of digital services to register and remit 7.5% VAT on services supplied to Nigerian users -- an explicit destination-principle application to crypto-adjacent services.
• Mining-as-a-service: If mining services are taxable (as in the
  UAE), the place-of-supply rules determine which jurisdiction's VAT applies.
• NFT sales: If NFTs are classified as electronically supplied services, the EU's place-of-supply rules for B2C digital services apply -- the supplier must charge VAT in the consumer's member state.

Practical challenges:

• Decentralized protocols have no identifiable supplier or jurisdiction of establishment
• Peer-to-peer transactions on DEXs may lack any intermediary on which to impose VAT collection obligations
• The EU's ViDA (VAT in the Digital Age) reforms may address some of these challenges, but are focused on e-commerce platforms rather than DeFi protocols specifically

5.4 NFTs and VAT

NFTs occupy a particularly uncertain position in the VAT/GST framework because they fail to meet the "payment instrument" or "currency" definitions that trigger exemptions for fungible tokens.

EU position (Working Paper No. 1060, 21 March 2023):

• NFTs are generally supplies of services, not goods
• If an NFT functions primarily as a digital artwork or collectible, the supply may constitute an electronically supplied service subject to standard-rate VAT
• If an NFT represents a title to a physical asset, the VAT treatment follows the underlying asset
• NFT creators/minters qualify as taxable persons if acting in the course of economic activity
• Belgium and Spain have already classified NFT sales as digital services subject to their standard VAT rates (21% each)

Australia: NFTs do not meet the section 195-1 definition of "digital currency" because they are non-fungible. Their GST treatment depends on specific circumstances -- they may be subject to 10% GST.

Singapore: NFTs do not qualify as "digital payment tokens" and therefore the GST exemption does not apply. Standard 9% GST may apply to NFT transaction fees and services.

Portugal: Income from NFTs is expressly excluded from the crypto tax regime (treated as outside the favorable crypto rules), though the AT could argue an other-category treatment for professional creators -- a direct-tax distinction that also shapes how indirect tax could attach.

Regulator takeaway: Regulators designing VAT/GST frameworks should explicitly address NFTs rather than relying on definitions crafted for fungible payment tokens. The emerging consensus is that NFT sales should be treated as taxable supplies of services, but significant uncertainty remains.

6. What Works and What Doesn't

What Works

1. The Hedqvist principle (currency-equivalent treatment): Treating payment-type crypto transfers as exempt financial transactions eliminates double taxation and aligns the VAT/GST treatment with fiat currency. This approach has been adopted -- through court ruling, legislation, or administrative guidance -- in virtually every major jurisdiction surveyed with a VAT.

2. Australia's legislative approach: Rather than relying on judicial interpretation,

   Australia legislated a clear definition of "digital currency" and explicitly disregarded it for GST purposes. The retrospective application (from 1 July 2017) ensured no gap in coverage. This provides a model for jurisdictions that lack a Hedqvist-equivalent judicial precedent.

3. Singapore's DPT framework:

   Singapore's approach of defining "digital payment tokens" in the GST Act and explicitly exempting their exchange is administratively clean. The clear definition avoids the ambiguity of relying on judicial analogy.

4. UAE's retroactive exemption: By backdating the virtual asset VAT exemption to 1 January 2018, the

   UAE eliminated retroactive VAT liability for early adopters and provided certainty. The decision to explicitly exclude mining from the exemption (VATP039, January 2025) demonstrates that targeted policy-making is possible even within a broad exemption framework.

5. Thailand's standing VAT exemption:

   Thailand's VAT exemption for transfers through SEC-licensed operators (Royal Decree No. 744, B.E. 2565/2022) carries no published expiry, providing long-term certainty for businesses and investors trading on licensed platforms.

What Doesn't Work

1. No guidance at all (

   South Korea,
   Brazil):
   South Korea has published no specific VAT guidance for crypto transactions, leaving treatment uncertain.
   Brazil similarly lacks standardized VAT treatment, with only ISS on service fees and an unresolved IOF-on-stablecoin debate. Regulatory silence creates compliance uncertainty and inconsistent enforcement.

2. No GST classification (

   India):
   India's GST Council has not classified VDAs for GST purposes, leaving crypto-to-crypto and crypto-to-fiat transfers in a regulatory grey zone; only 18% GST on exchange platform fees (from 7 July 2025) is settled.

3. Narrow definitions that exclude non-payment tokens:

   Australia's requirement for "fungibility" in the digital currency definition excludes NFTs.
   Singapore's DPT definition excludes utility tokens and NFTs. These gaps leave significant categories of digital assets without clear VAT/GST treatment.

4. Exemption without input tax credit recovery: Treating crypto services as "exempt" rather than "zero-rated" or "outside the scope" prevents businesses from recovering input VAT/GST, creating hidden costs. This is a structural issue in the

   EU,
   Australia, and
   Singapore.

5. Absence of DeFi guidance: No major jurisdiction has published comprehensive VAT/GST guidance on DeFi protocol interactions as of June 2026. This is the single largest gap in the global VAT/GST framework for digital assets.

6. Inconsistent mining and fee treatment: The

   UAE's decision to subject mining to 5% VAT, and
   Nigeria's 7.5% VAT on VASP fees, sit against the majority's outside-scope/exempt treatment, creating arbitrage incentives and complicating cross-border mining and platform operations.

7. Recommended Framework

Based on the comparative analysis, the following framework is recommended for regulators designing VAT/GST treatment of digital assets.

Principle 1: Payment Tokens Should Be Treated Equivalently to Money

Fungible, cryptographically secured tokens used as a medium of exchange should be exempt from VAT/GST on transfer, or supplies should be disregarded entirely. The rationale: these tokens perform the same economic function as fiat currency, and applying VAT/GST to their transfer creates double taxation.

Preferred mechanism: Disregard supplies (the Australian model) rather than exempt them (the EU model). Disregarding avoids the input tax credit restriction that accompanies exemption.

Principle 2: Explicitly Address Non-Payment Tokens

Regulators should not rely on payment-token definitions to cover the entire digital asset ecosystem. NFTs, utility tokens, governance tokens, and wrapped tokens should have explicit VAT/GST treatment -- either through an expanded definition or through separate guidance.

Principle 3: Mining and Staking Protocol Rewards Are Outside the Scope

Where miners or validators receive block rewards from a protocol (rather than fees from an identifiable customer), these rewards should be treated as outside the scope of VAT/GST. There is no supply of services to an identifiable recipient. This is the majority position internationally.

Exception: Mining-as-a-service and staking-as-a-service -- where a business provides computational services to an identifiable customer for a fee -- should be treated as taxable supplies of services (as in

France,

Germany,

Switzerland, and the

UAE).

Principle 4: Platform and Custody Fees Are Taxable Services

Fees charged by exchanges, custodians, and platforms for their services (distinct from the token transfer itself) should be subject to standard-rate VAT/GST. This aligns with the treatment of traditional financial service intermediary fees and ensures competitive neutrality. The

UK's narrower exemption for exchange-arrangement charges shows the alternative trade-off.

Principle 5: Address Cross-Border Services Using Existing B2C/B2B Rules

Apply existing OECD International VAT/GST Guidelines for cross-border digital services:

• B2B: Reverse-charge mechanism in the recipient's jurisdiction
• B2C: Destination principle, with simplified registration (e.g., EU OSS) for non-resident suppliers;
  Nigeria's 7.5% VAT on imported digital services is one example in practice.

Principle 6: Publish DeFi-Specific Guidance

Regulators should publish guidance addressing:

• Whether token swaps on DEXs constitute taxable supplies
• The VAT/GST treatment of liquidity provision (deposit and withdrawal)
• Whether DeFi lending constitutes an exempt financial service
• The identity of the supplier in automated protocol interactions

8. Decision Matrix

Regulators can use the following decision matrix when classifying a digital asset activity for VAT/GST purposes:

1. Is the token a fungible payment-type token (cryptocurrency)?
   YES --> Is the activity a transfer/exchange of the token?
           YES --> EXEMPT or DISREGARD (treat as money equivalent)
           NO  --> Go to Step 3
   NO  --> Go to Step 2

2. Is the token an NFT, utility token, or governance token?
   YES --> Does the activity involve supplying the token for consideration?
           YES --> LIKELY TAXABLE at standard rate (supply of services)
           NO  --> OUTSIDE SCOPE
   NO  --> Assess on a case-by-case basis

3. Is the activity a service provided in connection with tokens?
   (Mining-as-a-service, staking-as-a-service, custody, advisory,
    platform fees, exchange commissions)
   YES --> Is there an identifiable customer paying for the service?
           YES --> TAXABLE at standard rate (supply of services)
                   Exception: exchange arrangement fees may qualify
                   as exempt financial services in some jurisdictions
           NO  --> OUTSIDE SCOPE (e.g., solo mining, protocol staking)
   NO  --> OUTSIDE SCOPE

4. Is the activity a cross-border service?
   YES --> Apply B2B reverse-charge or B2C destination rules
           per OECD International VAT/GST Guidelines
   NO  --> Apply domestic rules from Steps 1-3

For cross-domain context on how these activities are classified for direct tax and reporting, see DeFi, Staking & Mining Tax and Cross-Border Reporting Frameworks.

Verification Notes

This is a refresh synthesis (modified 2026-06-04). All VAT/GST facts mirror the canonical per-jurisdiction fact matrix (t4: VAT/GST on crypto and services, exemption basis) for all 19 jurisdictions; no fact has been introduced that is not in the matrix or the prior verified version. Where the matrix records no specific treatment, this document reflects that honestly (e.g.,

South Korea no published VAT guidance;

Brazil no standardized VAT; NOT VERIFIED items not asserted as fact).

1. CJEU C-264/14 Hedqvist ruling: Judgment 22 October 2015, Fifth Chamber; VAT exemption under Art. 135(1)(e) of the VAT Directive (2006/112/EC). Binds all EU member states (

   France,
   Germany,
   Portugal); adopted administratively by the
   UK (R&C Brief 09/14) and
   Switzerland (ESTV, by analogy).

2. Australia GST: Digital currency supplies disregarded since 1 July 2017; Treasury Laws Amendment (2017 Measures No. 6) Act 2017; s 195-1 GST Act definition (fungibility requirement excludes NFTs).

3. Singapore DPT GST exemption: Effective 1 January 2020; GST (Amendment) Act 2019; standard 9% GST (from 1 Jan 2024) applies to non-DPT tokens (utility/NFT/security) services and fees.

4. UAE Cabinet Decision 100/2024: Transfer, conversion, and custody of virtual assets VAT-exempt, retroactive to 1 January 2018 (Art. 42 paras 2(k),(l),(m)); 5% VAT on mining per FTA Guidance VATP039 (January 2025), plus advisory and platform fees outside the exempt category.

5. UK CRYPTO45000: Crypto-to-fiat exchange exempt (financial transaction); mining outside scope ("insufficient link"); exchange-arrangement charges above token value exempt under Item 5, Sch 9, Grp 5, VATA 1994.

6. Japan consumption tax: Crypto transfers exempt since 1 July 2017 (Consumption Tax Act amendment); 10% consumption tax applies to exchange, lending, and advisory fees.

7. Canada GST/HST: Crypto used as payment treated as barter (both parties report FMV) under the Excise Tax Act; mining generally deemed a non-supply.

8. EU VAT Committee Working Paper No. 1060 (NFTs): Published 21 March 2023; non-binding; NFTs generally a supply of services / electronically supplied service. Belgium and Spain apply 21% standard VAT to NFT sales.

9. Thailand VAT exemption: Transfers through SEC-licensed operators VAT-exempt under Royal Decree No. 744 (B.E. 2565/2022); no published expiry; 7% VAT otherwise. (A separate Royal Decree No. 745 covers BOT retail CBDC transfers.)

10. South Africa VAT: Crypto buying/selling/exchanging VAT-exempt as a financial service (SARS clarified 2019); 15% VAT (standard rate from 1 April 2025) on advisory, platform, and consulting services.

11. Germany BMF VAT: Crypto-to-fiat and crypto-to-crypto exchange exempt (BMF letter 27 February 2018; Art. 135(1)(e)); mining for a third party for compensation may be subject to VAT.

12. India GST: Crypto transfers not directly subject to GST; 18% GST on exchange platform service fees from 7 July 2025; GST Council has not classified VDAs (no decision implemented as of June 2026).

13. Switzerland VAT: Crypto-to-fiat and crypto-to-crypto exchange exempt (ESTV; not bound by CJEU); third-party mining services may be subject to VAT at the 8.1% general rate (2025).

14. France VAT: Crypto-to-fiat exchange exempt (CJEU Hedqvist); mining services may be subject to VAT if supplied as a service for consideration.

15. Portugal VAT: Crypto-to-fiat exchange exempt (EU Hedqvist); mining VAT depends on service structure; NFT income expressly excluded from the crypto tax regime.

16. Nigeria VAT: 7.5% VAT on VASP/exchange transaction fees and on imported digital services (foreign providers must register and remit); no exemption (NTAA 2025; KuCoin began charging by July 2024).

17. El Salvador VAT: 0% VAT on Bitcoin transactions (legal-tender exemption); 0% VAT on CNAD-licensed digital asset transfers.

18. Brazil: No standardized VAT (ICMS/ISS/PIS-COFINS) applied to crypto transactions; ISS may apply to exchange service fees; IOF-on-stablecoin proposal not enacted.

19. South Korea: No specific VAT guidance; virtual assets not currently subject to VAT.

20. United States: No federal VAT/GST exists; VAT/GST treatment not applicable.

Sources

Court Decisions and Official Legal Texts

• EUR-Lex -- CJEU Case C-264/14 Skatteverket v David Hedqvist (22 October 2015)
• Norton Rose Fulbright -- ECJ rules that buying and selling Bitcoin is exempt from VAT
• Australian Treasury -- GST: removing the double taxation of digital currency
• Treasury Laws Amendment (2017 Measures No. 6) Act 2017 -- legislation.gov.au

Official Tax Authority Guidance

• HMRC -- CRYPTO45000: Value Added Tax (GOV.UK)
• IRAS -- Digital Payment Tokens (GST)
• IRAS -- e-Tax Guide: GST: Digital Payment Tokens (Second Edition)
• CRA -- Collecting and remitting GST/HST from crypto-asset transactions
• SARS -- Crypto Assets and Tax
• bitFlyer -- About Taxes Related to Bitcoin and Other Crypto Assets (Japan)

UAE Regulatory Sources

• KPMG -- UAE: VAT exemption does not apply to cryptocurrency mining (January 2025)
• VATupdate -- UAE Cabinet Decision No. 100: VAT Treatment of Virtual Assets Clarified
• EBS Chartered Accountants -- Amendments in UAE VAT Law below Cabinet Decision No. 100 of 2024

EU NFT and DeFi Sources

• EY -- EU VAT Committee publishes working paper on non-fungible tokens (Working Paper No. 1060)
• Springer -- VAT/GST harmonisation challenges for digital assets (PMC 2024)
• Cyplom -- NFT and VAT: Overview of the VAT qualification of an NFT (France and EU)

Germany

• BMF Circular of 6 March 2025 (English PDF)
• Acconsis -- Crypto Assets and VAT: What You Need to Know

Thailand

• HLB Thailand -- VAT relief extended for cryptocurrencies and utility tokens
• Legal 500 -- Thailand's digital asset market further boosted by exemption from 7% VAT

Australia Secondary Analysis

• HN Law -- Relief for GST Treatment of Digital Currencies in Australia
• Regulation Tomorrow -- Removing the double taxation of digital currency: start date 1 July 2017

Canada and Singapore

• BDO -- Singapore GST treatment for transactions involving digital payment tokens
• Canadian Tax Foundation -- New GST/HST Rules for Crypto Transactions

Switzerland

• Blockpit -- Crypto Taxes Switzerland 2026
• RSM Switzerland -- Cryptocurrencies for Individuals

India

• TaxGST.in -- Crypto Tax India 2026

South Africa

• TokenTax -- Guide to Crypto Taxes in South Africa for 2026
• Koinly -- Crypto Tax South Africa Guide 2026 </content>

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