Private ruling: P3D Tokens
Date of advice: 26 February 2019
Published: May 2019
Ruling period: Year ending 30 June 2018
Date scheme commenced: 01 July 2017

Ruling: Q1: When acquiring A tokens, is it acceptable to calculate the cost base of the tokens based on the value of the cryptocurrency B used to acquire the A token? | A1: Yes. Having considered your circumstances and the relevant factors the Commissioner considers it appropriate to accept a reasonable estimate of the value of cryptocurrency credited to the account. Further information can be found by searching 'QC 42159' on ato.gov.au | Q2: Is it correct to declare the cryptocurrency received from holding A tokens as ordinary income? | A2: Yes. Having considered your circumstances and the relevant factors the Commissioner considers that any cryptocurrency B received is assessable income, as receiving it is the reason for acquiring the A token. Further information can be found by searching 'QC 42159' on ato.gov.au

Relevant facts and circumstances: You acquired A tokens You acquired A tokens as an investment You have not disposed of any A tokens You receive a proportional amount of cryptocurrency B based on your holdings for every transaction that occurs on the platform.

Relevant legislative provisions: Income Tax Assessment Act 1997 section 6-5 | Income Tax Assessment Act 1997 section 104-10 | Income Tax Assessment Act 1997 section 108-5 | Income Tax Assessment Act 1997 section 108-20 | Income Tax Assessment Act 1997 section 108-25 | Income Tax Assessment Act 1997 section 110-25 | Income Tax Assessment Act 1997 section 116-20 | Income Tax Assessment Act 1997 section 118-10 | Income Tax Assessment Act 1997 section 118-20 | Tax Administration Act 1953