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Edited version of your written advice
Authorisation Number: 1051427234585
Date of advice: 26 February 2019
Ruling
Subject: P3D Tokens
Question
When acquiring A tokens, is it acceptable to calculate the cost base of the tokens based on the value of the cryptocurrency B used to acquire the A token?
Answer
Yes. Having considered your circumstances and the relevant factors the Commissioner considers it appropriate to accept a reasonable estimate of the value of cryptocurrency credited to the account. Further information can be found by searching 'QC 42159' on ato.gov.au
Question
Is it correct to declare the cryptocurrency received from holding A tokens as ordinary income?
Answer
Yes. Having considered your circumstances and the relevant factors the Commissioner considers that any cryptocurrency B received is assessable income, as receiving it is the reason for acquiring the A token. Further information can be found by searching 'QC 42159' on ato.gov.au
This ruling applies for the following period:
Year ending 30 June 2018
The scheme commences on:
01 July 2017
Relevant facts and circumstances
You acquired A tokens
You acquired A tokens as an investment
You have not disposed of any A tokens
You receive a proportional amount of cryptocurrency B based on your holdings for every transaction that occurs on the platform.
Relevant legislative provisions
Income Tax Assessment Act 1997 section 6-5
Income Tax Assessment Act 1997 section 104-10
Income Tax Assessment Act 1997 section 108-5
Income Tax Assessment Act 1997 section 108-20
Income Tax Assessment Act 1997 section 108-25
Income Tax Assessment Act 1997 section 110-25
Income Tax Assessment Act 1997 section 116-20
Income Tax Assessment Act 1997 section 118-10
Income Tax Assessment Act 1997 section 118-20
Tax Administration Act 1953