Administrative Policy
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 definition in subsection 123(1) was amended with effect from May 18, 2019, to include virtual payment instruments. The impact is that supplies of virtual payment instruments made on or after May 18, 2019, would be financial services under the ETA. Supplies of these types of cryptoassets made before May 18, 2019, are supplies of intangible personal property and are subject to the GST/HST.
Utility tokens and non-fungible tokens are cryptoassets but not virtual payment instruments (under “What is a cryptoasset?)
The cryptoasset definition in subsection 188.2(1) includes virtual payment instruments as well as property that may be excluded from the virtual payment instrument definition such as, utility tokens or non-fungible tokens.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Cryptoasset | 55 | |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Mining Activity | 118 | |
| Tax Topics - Excise Tax Act - Section 188.2 - Subsection 188.2(4) | 150 | |
| Tax Topics - Excise Tax Act - Section 188.2 - Subsection 188.2(2) | 365 | |
| Tax Topics - Excise Tax Act - Section 188.2 - Subsection 188.2(5) | 672 | |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Recipient | 208 | |
| Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(4) | 283 | |
| Tax Topics - Excise Tax Act - Section 200 - Subsection 200(2) | 427 | |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration | deduction from consideration paid by crypto pool operator to taxable supplier generally treated as such rather than as consideration for supply by operator | 101 |