TLDR: No, miners are not subject to VAT on cryptocurrency rewards awarded by the protocol, as there is no direct link between their activity and a specific beneficiary. However, if the miner receives fees freely agreed upon by the transaction beneficiaries, these amounts may be subject to VAT.
General principle of VAT exclusion
Mining involves using a computer's processing power to secure transactions on a blockchain. Miners are not legally bound to the network (Bitcoin, Ethereum, etc.) and do not need to join a protocol to carry out their activity. They simply invest in computer hardware and download open-source software.
Absence of a direct link with a beneficiary
Miners' remuneration comes from the system itself, not from the parties to the transaction. It is awarded randomly, only in the event of successful block validation. Under these conditions, it is not possible to identify an individual service provided for the benefit of a specific recipient. Therefore, in the absence of a direct link between the consideration and the mining activity, the latter does not fall within the scope of VAT.
Special case of fees
The VAT exclusion applies only when the remuneration is automatically awarded by the protocol. If the miner receives fees freely agreed upon by the transaction beneficiaries (for example, to speed up or prioritise the processing of a transaction), these amounts may be considered as a service subject to VAT.
Practical consequences
Miners do not need to collect VAT on the cryptocurrencies received as a reward for their mining activity. However, if they receive direct fees, they must assess whether these amounts fall within the scope of VAT, according to the general rules applicable to service provision.
Limits and precautions
This analysis only concerns VAT. Other tax obligations (income tax, declaration of economic activity, etc.) may apply independently. It is recommended to consult a professional for a personalised analysis.
Examples of distinct situations
The tax treatment may vary depending on whether the remuneration comes from the protocol or from third parties. Only rewards awarded by the system are excluded from the scope of VAT. Fees paid by third parties, on the other hand, may be taxable.