Where This Edition Fits

On December 22, 2022, the National Tax Agency published Tax Treatment of Crypto Assets (Information), the seventh crypto asset FAQ edition. It has 34 questions, just one more than the 33 in the December 22, 2021 edition.

Numerically, only one question was added. However, labels changed more substantially than content: sequential numbering from 1 onward was replaced by chapter-and-question numbering, such as 1-1, 1-2, and 1-3 instead of Questions 1, 2, and 3.

This matters when reading older materials. An explanation predating this edition that cites Question 9 no longer points directly to a number in the current FAQ.

Overview

How Did the Numbering Change?

Previously, questions ran from 1 to 33 across chapter boundaries. The first income tax question was 7 and the first corporation tax question 20, for example.

In this edition, chapters were numbered 1–7 and questions restarted within each. The first income tax question became 2-1 and the first corporation tax question 3-1, making the tax category immediately visible.

Apart from the one new question, chapter counts match the previous edition. The old-to-new mapping can therefore be read as follows.

Offsets differ by chapter: subtract 6 for income tax, 19 for corporation tax, and 30 for statutory returns to get this edition's question subnumber. One subtraction cannot convert every number.

Where Do Older References to Question Numbers Point?

Articles or books citing FAQ Question 9 or Question 22 use sequential numbering from before December 2022. Finding the ninth question in today's FAQ will not lead to the same content.

Complicating matters, renumbering did not stop there. New question 1-7 on nonresident and foreign corporate transactions is now 1-8 because December 2024 added 1-4 on donations, shifting all later numbers.

Current 1-7 is therefore a different question, acquisition through mining, staking, lending, and similar activities. The same 1-7 refers to different questions in December 2022 and the latest edition. Relying on the number alone causes confusion.

Corporation tax numbering changed further. This edition had six questions, 3-1 through 3-6. December 2023 split them into 3-1, Crypto Assets, and 3-2, Electronic Payment Instruments, creating three-part numbers such as 3-1-1. For the corporate tax approach, see Are companies taxed just by having them? summarizing in

Which Question Was Substantively New?

The only new question was 1-7, Crypto Asset Transactions by Nonresidents or Foreign Corporations. Behind the substantial visual renumbering, this was the sole addition in content.

It appears at the end of Chapter 1, common to individuals and corporations. Nonresident and foreign corporation refer to persons and entities outside Japan, and this was their first appearance in FAQ headings. Earlier editions were structured around individuals in Japan and Japanese corporations. This was the first question directly addressing cross-border transactions.

For crypto assets, the exchange, user's residence, and asset itself need not be in the same country, making the threshold question of Japanese taxation difficult. This question can be read as the first guide to that threshold.

For the order of analysis when considering crypto asset taxation, see Crypto-Asset Taxes: What Should You Read? I am organizing with.

Which Questions Are Marked Updated December 2022?

From December 2023, FAQ contents entries include Updated or Added month-and-year notes. Following them identifies when each question was revised.

The latest December 2025 contents mark the following six questions Updated December 2022. Numbers below are from the latest edition.

• 1-8 Crypto Asset Transactions by Nonresidents or Foreign Corporations, Added as 1-7 in December 2022
• 2-1 Timing of Gross Revenue Recognition for Income from Crypto Asset Transactions
• 2-3 Necessary Expenses for Crypto Assets
• 2-10 Treatment of Below-Market or Gratuitous Transfers and Similar Disposals of Crypto Assets
• 4-1 Acquisition of Crypto Assets by Inheritance or Gift
• 7-3 Whether Disclosure in the Statement of Foreign Assets Is Required

Two concern overseas matters: 1-8 and foreign assets statement question 7-3. This edition therefore addressed cross-border situations through both an addition and an update.

Income tax questions 2-1, 2-3, and 2-10 concern revenue timing, necessary expenses, and below-market or gratuitous disposals—core individual filing issues. Question 4-1 concerns inherited or gifted crypto assets, discussed in Receiving Crypto Assets by Inheritance or Gift. However, contents notes do not reveal exactly how each answer changed.

Was This Revision Accompanied by Tax Reform?

No reform accompanied it. Some annual tax reform outlines contain neither virtual currency nor crypto assets; FY2022 is one such year.

The dates nevertheless matter. On December 23, 2022, the day after this edition appeared, Cabinet approved the FY2023 outline, including exclusion of certain self-issued crypto assets from year-end market valuation.

Thus this FAQ appeared the day before an outline making major corporate tax changes. Those measures emerged as FAQ questions in December 2023, when corporation tax split into two sections and self-issued asset questions were added. For self-issued token treatment, see Will there be any inclusion income tax charged on tokens issued by myself? We are dealing with that.

This edition itself was not a rewrite prompted by legislative changes. It reorganized questions and added one overseas-related question. For the overall revision history, see History of Crypto Asset FAQ Revisions, while the immediately preceding edition is covered in December 2021 Edition summarizing in

Points that require care in practice

• If your material cites only Question X, use its date to determine whether it means sequential or chapter-based numbering. Materials before December 2022 use sequential numbers.
• The same number can refer to different questions across editions, as 1-7 shows. Record the heading as well as the number to avoid confusion.
• Corporation tax editions can be distinguished by two-part or three-part numbers: 3-1 predates December 2023, while 3-1-1 is from December 2023 onward.
• Using a Japanese exchange while living overseas may involve both the nonresident/foreign corporation question and the foreign assets statement question. Looking at only one can omit the other issue.
• An Updated note does not show what changed. Compare the PDFs before and after the revision to establish the differences.

Sources

• National Tax Agency: Tax Treatment of Crypto Assets (Information), December 22, 2022 PDF
• National Tax Agency: Archived Information on Crypto-Assets List