Private ruling: Assessable income - digital currency
Date of advice: 17 December 2025
Published: 9 February 2026
Ruling period: Year ended 30 June 20XX
Date scheme commenced: 1 July 20XX

Ruling: Q1: Is the income derived from the provision of digital services and sale of digital goods on an online platform assessable income under section 6-5 of the Income Tax Assessment Act 1997 (ITAA 1997)? | A1: Yes. | Q2: Is the income considered to be derived when credited to the platform account in accordance with subsection 6-5(4) ITAA 1997? | A2: Yes.

Relevant facts and circumstances: You carry on a business as a sole trader developing and selling digital assets and services on an online platform. You are paid in a digital currency specific to the platform. The digital currency is received directly from developers, studios or through sales on the platform Marketplace. The digital currency accumulates in your personal platform account, and at your discretion you convert the digital currency to Australian Dollars. The converted Australian Dollars is deposited in your Australian Bank account. You do not receive advertising or sponsorship income. You track digital currency balances and conversion rates. Statements from the platform are available upon each conversion to Australian Dollars.

Relevant legislative provisions: Income Tax Assessment Act 1997 section 6-5 | Income Tax Assessment Act 1997 subsection 6-5(4)

Reasons for decision: Summary: The income you earn from operating a business of developing and selling digital assets is ordinary income and assessable under 6-5 of the Income Tax Assessment Act 1997 (ITAA 1997). | Detailed Reasoning - Detailed reasoning: Under subsection 6-5(1) of the ITAA 1997 an amount is assessable income if it is income according to ordinary concepts (ordinary income). Ordinary income is generally understood to fall into three categories: • income from rendering personal services • income from property • income from carrying on a business Additional characteristics of income, as developed through case law, include receipts that: • are earned • are expected • are relied upon • have an element of periodicity, recurrence, or regularity In this case, you operate a business that develops and sells digital assets and services on an online platform. Income earned from carrying on a business is regarded as income according to ordinary concepts and is assessable under section 6-5 of the ITAA 1997 regardless of the form of payment. | Summary: The income is derived at the point the digital currency is credited to your online account as you are exercising control over how your income is dealt with in accordance with subsection 6-5(4) of theITAA 1997. | Detailed Reasoning - Detailed reasoning: Subsection 6-5(4) of the ITAA 1997 provides that you derive an amount of ordinary income as soon as it is applied or dealt with in any way on your behalf, or as you direct. That is, income is derived when it 'comes home' to the taxpayer in a realised or immediately realisable form (Commissioner of Taxes (SA) v. Executor Trustee and Agency Co of South Australia Ltd (1938) 63 CLR 108; [1938] HCA 69). Taxation Ruling TR 98/1 Income tax: determination of income; receipts versus earnings outlines the two principal methods of tax accounting for income: the receipts method and the earnings method. Paragraph 8 of TR 98/1 provides: 8. The 'receipts' method is sometimes called the 'cash received' basis or the 'cash' basis. Under the receipts method, income is derived when it is received, either actually or constructively, under subsection 6-5(4) of the ITAA 1997. The effect of that subsection is that income is taken to have been derived by a person although it is not actually paid over, but is dealt with on his/her behalf or as he/she directs. Further, paragraph 44 of TR 98/1 states: 44. Where an individual taxpayer, as opposed to a company (refer to paragraph 39), provides his/her knowledge or exercises skill as part of a business carried on by the taxpayer, the income of the business may represent a reward for the provision of those personal services. Where the income results primarily from the services rendered, or work performed by the taxpayer personally, it is generally assessable on a receipts basis. The principle of constructive receipt involves the notion of control of, or the capacity to control, an amount that is receivable or otherwise held in a matter satisfying the concept of derivation. In this case, you are paid in a digital currency specific to the online platform for providing your skills and knowledge as part of a business, developing and selling digital assets and services. The digital current accumulates in your personal account on the platform and at your discretion you convert the digital currency to Australian Dollars via a specific exchange, and the converted Australian Dollars is deposited in your Australian Bank account. As the digital currency is converted and resulting funds are withdrawn at your discretion, you are exercising control over how your income is dealt with. Consistent with paragraph 44 of TR 98/1, and in accordance with subsection 6-5(4) of theITAA 1997, the digital currency is assessable on receipts basis and is derived at the point it is credited to your online platform account as it is applied or dealt with as directed by you.