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The taxpayer inquired whether Bitcoin mining activities are subject to VAT and if they are entitled to VAT deductions. The DGT ruled that mining is not subject to the tax because there is no effective recipient or customer, as Bitcoins are generated automatically by the network.
Question raised: Liability for Value Added Tax regarding said activity. Right to deduction.
Mining activity is not subject to VAT as there is no direct relationship between the service provided and the consideration received, lacking an effective recipient or customer. As these are non-taxable operations and others that are taxable but exempt (transfer of Bitcoins), no right to deduct input VAT arises. The activity is subject to the Tax on Economic Activities.
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