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Answer #110: Issuetoken (Initial Coin Offering – ICO) – VAT treatment

An Initial Coin Offering (ICO) is the cryptocurrency industry’s equivalent to an Initial Public Offering (IPO). ICOs act as a way to raise funds, where a company looking to raise money to create a new coin, app, or service launches an ICO.

OPINION OF THE REVENUE AGENCY

At the time of issue, their function is different from that of a virtual currency, that – as stated by the Court of Justice in the judgment of 22 October 2015 (caseC-264/14, Hedqvist ) – has no “other purpose than that of a means of payment”(see paragraphs 49 and 52). It is therefore believed that in the present case the Company makes a provision ofservices pursuant to article 3, paragraph 1, of Presidential Decree 633 of 1972 by allowing access and use of the ALFA network and perform the activity of validator node..  As a generic service provision, it is taxable at the standard rate.

Source: gov.it

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