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VATP039 UAE

VATP039 UAE: Public Clarification on VAT Treatment on Cryptocurrency Mining in the UAE

The UAE has rapidly positioned itself as a global hub for digital assets, blockchain, and cryptocurrency innovation. With this growth, regulatory clarity has become essential for businesses and individuals operating in the sector. In April 2025, the Federal Tax Authority (FTA) issued VATP039 UAE, a pivotal public clarification addressing the VAT treatment of cryptocurrency mining in the UAE. This article will guide about anyone involved in crypto mining, whether as a personal or a business, as it defines how VAT applies to various mining activities. 



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Understanding the Scope 

VATP039 UAE  is designed to clarify the application of the UAE’s Value Added Tax (VAT) regime-established under Federal Decree-Law No. 8 of 2017 and Cabinet Decision No. 52 of 2017-to cryptocurrency mining. The clarification distinguishes between mining for personal use and mining as a service, providing much-needed guidance on cryptocurrency VAT UAE issues. 



Key Definitions from VATP039 UAE 

  • Virtual Assets: As per Article 1 of the Executive Regulation, virtual assets are digital representations of value that can be traded or transferred digitally and used for investment purposes. This does NOT include digital representations of fiat currencies or financial securities. 
  • Taxable Supply: Defined as the supply of goods or services for consideration in the course of business, excluding exempt supplies. 
  • Registrant: A taxable person who has been issued a Tax Registration Number (TRN). 



VAT Clarification on Cryptocurrency Mining: Two Scenarios 


1. Mining for Own Account (Personal Use)

If a person mines cryptocurrency for their own account, the activity is not considered a taxable supply. This is because there is no direct customer or consideration involved-the reward is allocated by the blockchain protocol itself. 

Key Points: 

  • No VAT on mining rewards: The act of mining for oneself is outside the scope of VAT. 
  • Input VAT is not recoverable: Any VAT paid on mining-related expenses (e.g., mining rigs, electricity, maintenance) cannot be reclaimed. This is because these costs are not incurred for making taxable supplies. 
  • Reference: “If a person is mining for his own account, the costs incurred would not be for the purpose of making taxable supplies. Consequently, as the person mining for his own account is not making a taxable supply, the input tax incurred cannot be recovered.” (VATP039 UAE, p.6) 


2. Mining as a Service (On Behalf of Others)

If a person or entity mines cryptocurrency on behalf of another party (as a service provider), this activity is considered a taxable supply of services under UAE VAT law. 

Key Points: 

  • VAT applies: The service provider must charge VAT (generally at 5%) on the fees earned from providing mining services to UAE residents. 
  • Input VAT is recoverable: VAT paid on expenses directly related to providing mining services can be reclaimed, provided supporting evidence (like tax invoices) is retained. 
  • Zero-rating for exports: If mining services are provided to non-residents and meet the conditions of Article 31 of the Executive Regulation, the supply may be zero-rated. 
  • Reference: “However, if the person acts as a service provider, and mines cryptocurrency on behalf of another person, the person may be eligible to recover the input tax to the extent the input tax is incurred for the purpose of making taxable supplies, provided that the relevant supporting evidence, e.g. tax invoices, are retained.” (VATP039 UAE, p.6) 



Additional VAT Considerations for Crypto Mining in the UAE 

  • Reverse Charge Mechanism 

If a UAE business receives mining services from a non-resident, the reverse charge mechanism applies. The UAE recipient must account for VAT as if they had supplied the service themselves. 

  • VAT Registration for Non-Residents 

Non-resident service providers who supply mining services to UAE customers (where no other party is responsible for the VAT) must register for VAT in the UAE. 

  • Legislative References 

The clarification draws from: 

  • Federal Decree-Law No. 8 of 2017 on VAT and its amendments 
  • Cabinet Decision No. 52 of 2017 on the Executive Regulation of the VAT law 



Summary Table: VAT on Crypto Mining Activities 

Activity Type  VAT Treatment  Input VAT Recovery 
Mining for Own Account  Outside VAT scope  Not recoverable 
Mining as a Service (for others)  Taxable supply (5% VAT)  Recoverable with evidence 



Why VATP039 UAE Matters for the Crypto Industry 

The introduction of VATP039 UAE brings much-needed certainty for miners, exchanges, and investors regarding UAE VAT and cryptocurrency. It ensures that businesses can structure their operations and tax planning in compliance with local regulations, avoiding costly mistakes and penalties. 

Key Takeaways: 

  • Mining for personal use is not taxable, and input VAT cannot be reclaimed. 
  • Mining as a service is taxable, and input VAT can be reclaimed with proper documentation. 
  • Non-residents providing mining services in the UAE may have VAT registration obligations. 



Conclusion 

The VATP039 UAE VAT clarification on cryptocurrency mining marks a significant step in aligning the UAE’s tax treatment of digital assets with international best practices. By distinguishing between personal and service-based mining, the FTA provides clear, actionable guidance for all participants in the crypto mining ecosystem. 

For anyone involved in crypto mining in the UAE, understanding these rules is essential for compliance and financial planning. As the digital economy evolves, hiring a Professionals VAT consultant in Dubai  provides guidance on the proper VAT treatment of crypto mining activities and guarantees compliance with UAE VAT legal guidelines to keep away from penalties. 



FAQs 


What is VATP039 UAE?

VATP039 UAE is a public clarification issued by the UAE Federal Tax Authority in April 2025 that explains the VAT treatment of cryptocurrency mining activities in the UAE. 


Is cryptocurrency mining subject to VAT in the UAE?

It depends on the nature of the mining activity: 

Mining for personal use is outside the scope of VAT. 

Mining as a service (on behalf of others) is a taxable supply subject to 5% VAT. 

Can input VAT on mining-related expenses be recovered?

For personal mining, input VAT on expenses like electricity and hardware cannot be recovered. 

For mining services provided to others, input VAT can be recovered if the expenses relate to taxable supplies and proper documentation is maintained. 

Do non-resident crypto miners need to register for VAT in the UAE?

Yes, if non-resident miners provide mining services to UAE clients and no other party is responsible for VAT, they must register for VAT in the UAE. 


How does the reverse charge mechanism apply to crypto mining services?

If a UAE business receives mining services from a non-resident provider, it must account for VAT under the reverse charge mechanism, effectively self-accounting for the VAT due. 


Are mining rewards considered taxable income under VAT?

No, mining rewards received by individuals mining for their own account are not considered taxable supplies and are outside the scope of VAT.