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V1748-18 18 June 2018 · SG de Impuestos sobre el Consumo Criterion in force
IVA · minado de bitcoins

Bitcoin mining is exempt from VAT and does not establish entrepreneurial status

The consultant asks whether Bitcoin mining is subject to VAT and whether VAT deductions are allowed for components purchased. The DGT states that Bitcoin mining is not an entrepreneurial activity subject to tax and therefore does not entitle the taxpayer to deduct VAT on purchases.

The question raised

Liability for Value Added Tax regarding said activity. Right to deduction.

The DGT's ruling

Bitcoin mining operations are not subject to VAT because there is no direct relationship between the service provided and the consideration received, as no effective recipient is identified. Mining does not confer the status of entrepreneur or professional. Since no taxable and non-exempt operations are carried out, the right to deduct input VAT is not generated pursuant to Article 94.One of Law 37/1992.

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