Where This Edition Fits

This edition was published June 30, 2021. The National Tax Agency index links to it as Tax Treatment of Crypto Assets (Information). It contains 33 questions.

The preceding December 18, 2020 edition had 32, so one question was added after just over six months. One other heading changed; those were the only two locations affected.

A feature stands out even before the content:it was published in June.There have been ten editions from December 2017 through the latest December 2025 edition, and this is the only one published midyear.

Overview

Why June Rather Than December?

The ten publication dates show this edition's position: December 1, 2017; November 21, 2018; December 20, 2019; December 18, 2020; June 30, 2021; December 22, 2021; December 22, 2022; December 25, 2023; December 20, 2024; and December 26, 2025.

Nine of ten editions cluster between late November and late December, maintaining a year-end revision pattern from the first edition. June 30, 2021 is the exception.

That year also had a December revision, published December 22, 2021, six months later.2021 Is the Only Year with Two Revisions

The National Tax Agency does not explain the June timing in this FAQ or later editions. Without speculating, we can say only that these two locations were amended before waiting for the next annual revision.

What Does the New Question Cover?

The addition is Question 30, Fees for Lending Crypto Assets, under consumption tax.

Crypto asset lending means lending holdings to another person for a fixed period and receiving a fee. The lent assets are returned at the end. This is not a sale and therefore not a disposal in that form.

Previously, consumption tax had only one question, on transferring crypto assets—selling them. This edition added lending alongside it.

The pairing has a consumption tax rationale. FY2017 reform made transfers of virtual currencies defined by the Payment Services Act exempt from consumption tax.The prescribed treatment concerned transfers.Lending for a fee is not the transfer itself.

The crypto asset consumption tax framework is discussed in Selling crypto assets does not incur consumption tax. This edition adds a question about a transaction adjacent to that framework.

What Does Adding Gratuitous and Similar Disposals Indicate?

The other change is Question 16's heading, from Treatment of Below-Market Transfers of Crypto Assets to Treatment of Below-Market or Gratuitous Transfers and Similar Disposals of Crypto Assets.

The additions are gratuitous in parentheses and similar disposals. The previous heading referred to selling cheaply; the new one expressly includes receiving no consideration.

Expanded heading language and changes in the answer are separate matters. This article establishes only what appears in the heading: gratuitous transfers became explicit in the FAQ's contents.

Gratuitous transfers were later differentiated further. The latest December 2025 edition has a separate 1-4, Donations in Crypto Assets, added in December 2024.

Why Revise Without Tax Reform?

Neither crypto assets nor virtual currency appears in the FY2021 outline, and the same is true for FY2022. This edition was not issued because the law changed.

Earlier revisions connected to tax reform. The FY2019 outline prescribed individual acquisition-cost valuation using moving or total averages and introduced corporate market valuation. This corresponds to the December 20, 2019 expansion from 21 to 32 questions. The terminology change from virtual currency to crypto assets also followed amendments to the Payment Services Act and related laws.

This edition differs, appearing to respond to transaction developments rather than legislation. Six months later, December 22, 2021 changed Question 6 from mining acquisition to mining, staking, lending, and similar acquisition. Lending thus also appeared in an income calculation question.

The sequence was June addressing lending for consumption tax, then December naming the same transaction for income tax. For acquisition through mining and similar activities, see Acquisition Through Mining and Similar Activities We are dealing with that.

Points that require care in practice

• There are two 2021 editions, June 30 and December 22, both with 33 questions. Count alone cannot distinguish them. If Question 6's heading includes lending, it is the December edition.
• Question numbers shifted. Adding 30 moved the three assets and liabilities and foreign assets statement questions to 31–33. A document citing 30, Whether an Assets and Liabilities Statement Entry Is Required, uses numbering from December 2020 or earlier.
• The latest edition uses a different numbering system. From December 2022, sequential numbers became chapter-and-question numbers. This edition's Question 16 is 2-10 in December 2025; its Question 30 is 6-2.
• Adding the question means the issue had not previously appeared in this National Tax Agency text. Consult the PDF below for the answer. This article covers only which questions changed.
• The June publication date also matters for records. When reviewing which guidance was consulted for a 2021 return, distinguish the June 30 and December 22 editions.

For a complete history, see History of Crypto Asset FAQ Revisions; for the adjacent editions, see December 2020 Edition and December 2021 Edition Please see

Sources

• National Tax Agency: Tax Treatment of Crypto Assets (Information), June 30, 2021 PDF
• National Tax Agency: Archived Information on Crypto-Assets List