ITALIAN INDIRECT TAXATION IN THE ISSUE OF UTILITY TOKENS

Italian Tax Agency, with ruling no. 110 of 2020 clarified that, from a VAT point of view, the issue of utility tokens relies on the specific characteristics of the very single token.

In particular, utility tokens, which allow the purchase of goods and services on a given blockchain infrastructure, show strong similarities with the digital coupons (so-called voucher) which, we point out, can be divided according to their “single-use” or “multi-use” function. While single-purpose vouchers are representative of determined goods and services, subject to VAT when the coupon is issued (the sale of the voucher counts as the sale of theunderneath goods and services), the multi-use coupons are, basically, a payment method, therefore not subject to VAT when it’s issued, instead when it’s used (when it will be possible to identify the specific good or service and, therefore, the proper VAT rate to apply).

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