L’IVA (Imposta sul Valore Aggiunto) è un tipo di imposta indiretta che ha ad oggetto, il valore aggiunto della produzione/scambio di beni o servizi.
È importante cominciare ad analizzare come l’IVA possa interessare il mondo delle criptovalute, in modo da comprendere quando e come, essa entra in gioco.
-OPERAZIONI ESENTI DA IVA
L’Agenzia delle Entrate, con la Risoluzione n.72/E, analizza la “commercializzazione di Bitcoin eseguita da Exchanger”, disponendo che questo tipo di attività, risulta come ATTIVITÀ RILEVANTE AI FINI IVA, ma ESENTE ai sensi dell’art 10, c. 1 n.3) d.P.R. 633/1972.
L’interpretazione in questo modo fornita dall’ADE, è coerente e concorde con l’interpretazione a sua volta fornita dalla Corte di Giustizia Europea, nell’ambito della Sentenza 22/10/2015 (Causa C-264/14), ove definisce i Bitcoin come MEZZI DI PAGAMENTO.
Pertanto, definendoli come tali, considera ESENTI le PRESTAZIONI DI SERVIZI DI CAMBIO VALUTE.
Inoltre, è corretto considerare ESENTE anche il Servizio di MESSA A DISPOSIZIONE DI DIGITAL WALLET.
-OPERAZIONI SOGGETTE A IVA
Andiamo ad analizzare adesso, esempi di operazioni che invece sono assoggettate ad imposizione IVA:
“L’offerta di servizi Trading Crypto da parte delle Società”, viene inquadrata tra quelle attività che sono soggette al REGIME IVA ORDINARIO.
Di conseguenza, l’attività di intermediazione di valute virtuale, svolta in modo professionale ed abituale, costituisce un’attività rilevante ai fini IVA.
L’emissione di Utility Token (diritto ricevere servizio/bene) da parte di Società, NON HA RILEVANZA AI FINI IVA.
Nemmeno la sua circolazione successiva avrà rilevanza.
Sarà invece soggetto ad IVA, l’operazione con il quale l’acquirente usufruirà del diritto che l’utility token gli garantisce, ricevendo il bene o il servizio in questione.
Questa interpretazione appena descritta, viene rinvenuta all’interno dell’Interpello n.14 del 28/09/2018.
A ulteriore conferma, ricordiamo anche la risposta all’Interpello n.110 del 2020.
In conclusione dunque, possiamo vedere come la messa a disposizione di piattaforme online in cui l’utente può eseguire attività o operazioni di acquisto/vendita di cripto-attività, vengono fatte ricadere sotto la sfera di applicabilità IVA, soggette ad aliquota ordinaria.
–IVA E PAGAMENTI EFFETTUATI IN CRIPTOVALUTE
Le cripto-attività non sono oggetto di nessuna esplicita disposizione riguardante l’imposta IVA.
Anche le informazioni fornite dall’Unione Europea in relazione a come trattare l’IVA in materia di Crypto-Attività, sono esigue.
Come precedentemente evidenziato, la Corte di giustizia dell’Unione Europea ha stabilito, che lo scambio di Bitcoin per una valuta tradizionale è una prestazione di servizi esente da Iva ai sensi dell’articolo 135, paragrafo 1, lettera e), della direttiva Iva,.
Quando sono usate come mezzo di pagamento contrattuale dunque, in assenza di alcuna espressa normativa a riguardo, possiamo dedurre un’esenzione IVA sulle prestazioni saldate attraverso le criptovalute.
Dunque, ad esempio, erogare prestazioni professionali in UE ottenendo pagamenti in criptomonete, in attesa di aggiornamenti futuri normativi in tema, deve intendersi come attività esenti da IVA.
Se desideri ricevere una consulenza:
https://www.cryptolegaltech.com/consulenze/
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