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Ruling 508: Mining activities -processing for direct tax and VAT purposes

Mining is not relevant for VAT purposes as it is characterized by the absence of a synallagmatic link with consequent preclusion of the right to deduct.

The Revenue Agency emphasizes that the miner 5 ‘reward’ is automatically attributed by the “system / network / network’, given that the underlying technology is characterized by the absence of a subject that can be considered a client of the service.  As such, the activity cannot be subject to VAT. The irrelevance for tax purposes it derives, in fact, from the absence of a synallagmatic relationship, since the service cannot be said to be “directly provided by the miner to a specific or determinable customer’. The VAT paid on purchases is consequently not deductible .

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