Cryptocurrencies and new legal events in tax law: mining, staking, and airdrop

Abstract

This study examines three acquisition methods of cryptocurrencies – mining, staking, and airdrop – and raises the question of how these methods are treated under the current tax legislation, specifically in the context of the Personal Income Tax Act (PITA). It attempts to analyze the civil law nature of these acquisition methods in order to clarify whether and under what conditions they may fall within the scope of existing tax law as taxable events. The analysis considers the specific grounds for acquisition in light of the principle of legality of taxation, the permissible methods of interpretation in tax law, and the prohibition of applying tax norms by analogy in the absence of explicit legal regulation. The conclusion supports the need for legislative clarification of the legal regime governing cryptocurrency acquisition methods, in order to ensure legal certainty and predictability for taxpayers.