Relevant Period:This article discusses the National Tax Agency's December 25, 2023 materials and subsequent revision history. Consult the latest edition for current treatment.

Where This Edition Fits

On December 25, 2023, the National Tax Agency published Tax Treatment of Crypto Assets and Similar Assets (Information), the eighth crypto asset FAQ edition.

It contains 45 questions, up 11 from the 34 in the December 22, 2022 edition, substantially expanding corporation tax guidance.

All 11 additions are in the corporation tax chapter. The individual-related chapter counts are unchanged. This edition can be read as redefining the boundaries for valuing corporate crypto asset holdings at year-end.

Overview

Why Was Corporation Tax Divided in Two?

The previous edition had six corporation tax questions, 3-1 through 3-6. This edition first split the chapter into 3-1, Crypto Assets, and 3-2, Electronic Payment Instruments, then renumbered the questions beneath them. This division explains the move from two-part to three-part numbering.

The four questions in 3-2 follow acquisition, disposal, and year-end in chronological order, ending with foreign-currency instruments.

• 3-2-1 Tax Treatment on Acquisition of Electronic Payment Instruments
• 3-2-2 Tax Treatment on Disposal of Electronic Payment Instruments
• 3-2-3 Year-End Tax Treatment of Electronic Payment Instruments
• 3-2-4 Year-End Tax Treatment of Foreign-Currency Electronic Payment Instruments

Electronic payment instruments is the legal term for so-called stablecoins. A separate section was needed because the Payment Services Act's definition of crypto assets excludes electronic payment instruments. Reading crypto asset questions alone does not establish their treatment. For definitions, see How does the tax law define "cryptoassets"? We are dealing with that.

What Boundaries Do the Seven New Questions in 3-1 Draw?

The following seven questions were added to 3-1.

• 3-1-4 Crypto Assets with an Active Market
• 3-1-5 Crypto Assets Traded on DEXs
• 3-1-6 Year-End Mark-to-Market Valuation of Crypto Assets Locked for Staking
• 3-1-7 Year-End Mark-to-Market Valuation of Lent Crypto Assets
• 3-1-8 Year-End Mark-to-Market Valuation of Borrowed Crypto Assets
• 3-1-9 Crypto Assets Qualifying as Specified Self-Issued Crypto Assets
• 3-1-10 Crypto Assets Jointly Issued by Multiple Businesses

Year-end mark-to-market valuation of corporate crypto holdings was introduced by FY2019 tax reform. The outline requires corporations to recognize valuation gains and losses on year-end virtual currency holdings with an active market. This began the treatment of recognizing gains or losses merely from holding assets at year-end without selling them. For an overview, see Are companies taxed just by having them? summarizing in

The first five additions examine the scope of that mechanism. Question 3-1-4 addresses the initial test: what constitutes an active market. Article 118-7 of the Order for Enforcement of the Corporation Tax Act requires continuously published trading prices and transactions of sufficient volume and frequency to support that publication, among other conditions. For interpreting these requirements, see What is "an active market for crypto assets"? in detail.

Question 3-1-5 applies the threshold to trading outside an exchange. Questions 3-1-6 through 3-1-8 test different forms of holding: assets locked for staking, lent to others, and borrowed from others. None is simply freely saleable property in hand, yet each now has a separate question on year-end valuation.

Which Amendment Led to 3-1-9?

Question 3-1-9, Crypto Assets Qualifying as Specified Self-Issued Crypto Assets, derives from FY2023 tax reform. Its outline, Cabinet-approved on December 23, 2022, excludes corporate year-end crypto holdings meeting two requirements from recognition of mark-to-market gains and losses.

• The crypto asset must be self-issued and continuously held from issuance.
• Transfer restrictions must apply continuously from issuance, either through technical measures preventing transfer to others or through holding as trust property under a trust meeting prescribed conditions.

The same outline sets the acquisition cost of self-issued crypto assets at issuance expenses. It also requires deemed repurchase and recognition of corresponding gains or losses where assets borrowed from someone other than a crypto asset exchange are disposed of and not repurchased in the same type by year-end. In a year when the outline addressed borrowing, FAQ question 3-1-8 was added as well.

The previous edition was published December 22, 2022, the day before Cabinet approved this outline, explaining why it did not reflect the amendment. Self-issued token treatment is discussed in Will there be any inclusion income tax charged on tokens issued by myself?. Adjacent question 3-1-10, Crypto Assets Jointly Issued by Multiple Businesses, addresses the scope of self-issued.

What Do the Contents Notes Make Visible?

From this edition, each contents entry ends with an Updated or Added month-and-year note, enabling readers to trace when a question changed.

However, each entry retains only one note, replaced by the latest. In the current December 2025 contents, only six questions retain Added December 2023: 3-1-9, 3-1-10, and 3-2-1 through 3-2-4. The other five additions now show Updated December 2024, so their addition date is no longer visible from the contents.

Updates can also be identified from the contents. Seven questions in the latest contents show Updated December 2023: 3-1-1 on recognition timing for crypto asset disposal gains and losses, margin transaction questions 3-1-12 and 3-1-14, consumption tax questions 6-1 and 6-2, and assets and liabilities statement questions 7-1 and 7-2. These latest-edition numbers differ from those in this edition. For the overall revision history, see History of Crypto Asset FAQ Revisions, while the immediately preceding edition is covered in December 2022 Edition summarizing in

Points that require care in practice

• The relevant chapter depends on whether the asset is a crypto asset or electronic payment instrument. Appearance or informal names do not determine the boundary; check issuer explanations and registration classifications.
• Assets locked for staking or lent out may feel beyond your possession, but each has its own year-end valuation question. Being unable to move an asset does not mean it is excluded from valuation.
• Crypto asset lending across a year-end raises questions for both lender and borrower. Establish the contractual details from your company's perspective.
• For self-issued tokens, the key is evidence of the restriction method and its uninterrupted application from issuance. If the start date cannot later be verified, explaining eligibility becomes difficult.
• For jointly issued tokens, whose asset qualifies as self-issued is not self-evident. Review how the issuer was defined in the original issuance arrangements.
• Contents notes retain only the latest change. To establish when a question was added, open the PDF for that historical edition.

Sources

• National Tax Agency: Tax Treatment of Crypto Assets and Similar Assets (Information), December 25, 2023 PDF
• National Tax Agency: Archived Information on Crypto-Assets List