Where This Edition Fits

On December 22, 2021, the National Tax Agency published Tax Treatment of Crypto Assets (Information), its sixth crypto asset FAQ edition. The previous edition was June 30 of the same year, less than six months earlier.

There are 33 questions, unchanged from June 30, 2021, and the chapters from common income and corporation tax matters through statutory returns are also unchanged. Only two question headings changed.

However, one change goes beyond a simple retitling. A question previously focused only on mining expanded to cover staking and lending. This article examines that question.

Overview

How Did Question 6's Heading Change?

The previous heading was Acquiring Crypto Assets Through Mining. It became Acquiring Crypto Assets Through Mining, Staking, Lending, and Similar Activities.

Comparing them reveals three changes.

• Acquisition methods increased from one to three, adding staking and lending to mining.
• The wording and similar activities was added, indicating that the list is not exhaustive.
• The Japanese word order changed. Previously crypto assets came first, with the acquisition method in the middle. The new heading leads with the methods and puts acquisition of crypto assets afterward, shifting emphasis from the asset itself to how it is acquired.

Staking involves depositing crypto assets while continuing to hold them and receiving rewards. Lending involves lending assets and receiving usage fees. Both increase crypto assets while retaining the holding or expecting repayment, rather than disposing of them for consideration.

The question appears in common income and corporation tax matters, expanding an initial issue relevant to both individuals and companies. The basic approach to mining acquisitions is discussed in Acquiring Crypto Assets Through Mining and Similar Activities summarizing in

More Ways to Acquire Assets Without Buying or Issuing Them

Crypto asset acquisition has broadly been divided into purchases, self-issuance, and other acquisition. Cost determination is structured around these three categories. For details, see How is the acquisition price of crypto assets held by individuals determined? Please see

Mining, staking, and lending fall into the third category: assets increase without purchase or self-issuance. Before this edition, Question 6 named only mining as one route within that category.

The revision added two named routes to the third category. Including and similar activities also leaves room for unnamed forms. The heading reflects that crypto asset acquisition had expanded beyond what purchases and issuance alone could explain.

How Does This Connect to the Revision Six Months Earlier?

The preceding June 30, 2021 edition added consumption tax Question 30, Fees for Lending Crypto Assets. Lending for a fee was thus first addressed from the consumption tax perspective.

Six months later, this edition added staking and lending to common income and corporation tax Question 6. The sequence addresses the same increase through lending first for consumption tax, then for income taxation.

Consumption tax on crypto asset transfers is discussed in Selling crypto assets does not incur consumption tax. The two 2021 revisions can be viewed as addressing both sides.

Did Question 25's New Heading Change the Treatment?

The other change was corporation tax Question 25, from Year-End Deemed Settlement Gains and Losses on Crypto Asset Margin Transactions to Amount of Deemed Settlement Gains and Losses on Crypto Asset Margin Transactions.

Year-end was removed and amount added, dropping the timing reference and emphasizing the calculated monetary result. This is terminology clarification rather than a change in treatment. For margin transaction principles, see Credit trading of crypto assets We are dealing with that.

In the latest December 2025 contents, two questions are marked Updated December 2021: 1-7 and 3-1-13. The former is the renumbered Question 6, but 3-1-13 concerns recognition timing for margin transaction disposal gains and losses. The deemed settlement amount question, 3-1-14, carries another year's note. We have not confirmed the correspondence between these notes and the two headings changed in this edition.

Was This Revision Accompanied by Tax Reform?

No accompanying reform. Reviewing outlines from FY2010 onward reveals years with neither virtual currency nor crypto assets mentioned. FY2021 and FY2022 are both such years.

Thus this revision was not prompted by legislative changes. Transaction forms had expanded ahead of changes in the law, and an existing question was broadened to accommodate them.

Some crypto asset FAQ editions are substantially restructured by tax reform; others are not. For the overall history, see History of Crypto Asset FAQ Revisions, while the immediately preceding edition is covered in June 2021 Edition. In the next December 2022 edition, sequential question numbers change to chapter-and-question numbers, substantially altering references.

Points that require care in practice

• Valuing crypto rewards from staking or lending depends on identifying receipt dates. First check whether exchange histories retain reward credit dates.
• Daily small rewards create large numbers of records. The workload differs greatly depending on whether they appear in annual transaction reports or require your own records.
• The heading does not identify everything covered by and similar activities. For new unnamed forms of receipt, examine the contract to determine their similarity to mining, staking, or lending.
• Lending has separate income tax and consumption tax questions. Reviewing only one can omit the other analysis.
• Question 25's retitling clarifies terminology, but the issue of corporate unsettled margin positions at year-end remains. Do not confuse a heading change with a treatment change.

Sources

• National Tax Agency: Tax Treatment of Crypto Assets (Information), December 22, 2021 PDF
• National Tax Agency: Archived Information on Crypto-Assets List