GST/HST Notice No. 324, "Mining Assets in respect of Cryptoassets" June 2025

Supplies of virtual payment instruments ceased to be taxable on or after May 18, 2019 (under “What is a cryptoasset?)

The financial instrument...

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Utility tokens and non-fungible tokens are cryptoassets but not virtual payment instruments (under “What is a cryptoasset?)

The cryptoasset...

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Mining activity includes executing proof-of-stake protocols and use of mining equipment (under “What is a mining activity?”)

The definition...

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No GST collectible re mining activity including generating network block subsidies (under “Collection of tax”)

Subject to the exclusion in...

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Denial of ITCs by virtue of ss. 188.2(2) and (3) (under “Eligibility for ITCs”)

Subject to the exclusion in subsection 188.2(5), to the extent...

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Under “Mining groups and mining group operators”

Example 1

Corporation A owns computing equipment for use in mining activities. Corporation B...

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Prior to s. 188.2(2), mining was commercial activity with no recipient of the supply (under “Solo Miners” and "Collection of tax")

On a...

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Application of s. 141.01(4) to crypto mining (which is not a taxable supply because no recipient) where there is a view to sale of the crypto...

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Application of change-in-use rules as a result of virtual payment instruments becoming financial instruments on May 18, 2019 under "ITCs where...

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Under “Mining groups and mining group operators”

• Where a person makes a supply to a crypto pool operator that is subject to the general rules...

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