Private ruling: Cryptocurrency trading business
Date of advice: 26 October 2021
Published: February 2022
Ruling period: Year ending 30 June XXXX
Date scheme commenced: 1 July XXXX

Ruling: Q1: Are you carrying on a business of cryptocurrency trading? | A1: Yes. You are carrying on a business of cryptocurrency. Based on the facts and circumstances given below you meet the requirements of Taxation Ruling TR 97/11 - Am I carrying on a business.

Relevant facts and circumstances: • You started cryptocurrency mining in mid-XXXX. • You bought XXXX cryptocurrency to buy mining related software but did not proceed with the purchase and so still have it. • You usually do not buy but only mine cryptocurrencies. • You mine XXX and XXX cryptocurrencies. • Your intention is to pay off mining equipment purchases and make an income of $X per year. • Turnover of Cryptocurrencies sold for financial years XXXX, XXXX, XXXX and XXXX was zero but for XXXX it was $X. • You have a business plan, set budgets and targets and keep records of the cryptocurrency transactions of mining and selling. • You do accounting for the cryptocurrency's transactions on a gross receipts' basis. • For the financial years XXXX, XXXX and XXXX you invested $X, $X and $X respectively to buy graphics cards, tools, software, motherboard, power supplies etc. • You have an office room and a separate mining room where most of the mining equipment is running. • At the present time you intend to keep XXXX as you think it may increase in value. • You sold some cryptocurrency in XXXX for a profit. Most of the cryptocurrency sold was mined in XXXX. • You mined X, X, X (No mining) and X of X cryptocurrency in XXXX, XXXX, XXXX and XXXX financial years respectively. • You have fulltime employment. • You also run an IT busines.

Relevant legislative provisions: Taxation Ruling TR 97/11