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Italy update on VAT and Crypto assets

Exemption for tokens and mining from rulings

Italy has confirmed that both crypto utility tokens and mining are exempt from VAT. This follows EU VAT Committee crypto asset VAT preliminary review.


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In two rulings, the following guidance was issued:

  • Currency Mining or Forging  is exempt (Risposta n.º 508/2022 from Agenzia delle Entrate) since there is no provision of services to an attributable customer – as required for VAT to be liable.
  • Utility Tokens are exempt from VAT at the point of issuance and should not be treated as regular VAT voucher since their purpose can change (Risposta n.º 507/2022 from Agenzia delle Entrate). The case concerns a service creating a blockchain token certifying that a piece of music was original.

On 17 October, a further letter, 515/2022, confirmed mining as exempt from VAT.

At the member state level, confirmation on Belgium Non-Fungible Token VAT and Spain VAT NFT has already been issued.


VAT on cryptocurrencies

Stage Examples VAT Treatment
Crypto-assets Payment, security or utility tokens Treated as currency
Creation of tokens Mining or forging Out of scope of VAT
Supplies free of charge Airdrop Out of scope of VAT
Supplies for consideration Taxable; but exempt
Storage and transfer Hot or cold digital wallets Taxable; but exempt
Exchange for crypto-assets or cryptocurrencies Taxable; but exempt
Cryptocurrencies as consideration for supply Taxable; VAT due
Token modification Modifications, forks or splitting of tokens Out of scope of VAT


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