仮想通貨売買所得は事業所得になり得るか

仮想通貨の売買益は、「雑所得で申告」と決まっているわけではありません。

仮想通貨を使用することによる損益は、事業所得等の各種所得の起因となる行為に付随して生じる場合を除き、原則として、雑所得として区分されることとしていますが、例えば、事業所得者が、事業用資産としてビットコインを保有し、決済手段として使用している場合に、その使用により生じた損益については、事業に付随して生じた所得と考えられますので、その所得区分は事業所得となります。

その他、例えば、その収入によって生計を立てていることが客観的に明らかであるなど、その仮想通貨取引が事業として行われていると認められる場合にも、その所得区分は事業所得よなります。

 (国税庁個人課税課 「仮想通貨に関する所得の計算方法等について(情報)より)

つまり、事業の決済手段 例えば商品仕入れるときに仮想通貨で支払ったり、売上の対価を仮想通貨で受け取った場合に発生する損益は、事業所得ということになります。

また、その収入によって生計を立てていることが明らかな場合は事業所得となる、ということです。

事業所得となる所得の考え方は通常以下のとおりです。

①自己の危険と計算において、独立的に営まれている事業であること。②営利を目的とし、有償性を有すること。 ③反復継続して遂行する意思と社会的地位とが客観的に認められる。

仮想通貨取引についてこの基準は次のように考えられるのではないかと思います。

①自己の危険と計算において、独立的に営まれている事業であること。

自己の判断で自らリスクを負って資金を投入し、独立して取引行為を行っていれば、該当すると考えていい。

②営利を目的とし、有償性を有すること。

取引判断について、営利を目的としているといえるだけの何らかの取引基準があり、実際の資金を投じて行っている場合にはこの基準は満たしていると考えられるのではないか。

③反復継続して遂行する意思と社会的地位とが客観的に認められる。

問題は、ココ!「反復継続して遂行する意思」というのは以前に買ったビットコインなど仮想通貨を寝かせておいたら、数年後に100倍になった、

ということでは、ダメなんです。

事業を行う意思で、何度も何度も反復継続して、何らかの判断基準に基づいて取引していることが明らかであるような場合は「反復継続して遂行する意思がある」と考えられます。

「仮想通貨に関する所得の計算方法等について(情報)」の中で示された「その収入によって生計を立てていることが客観的に明らかである場合」というのが一般的に言う「社会的地位とが客観的に認めらる」ということだと思いますので

仮想通貨取引を、一定の論理に基づき反復継続して行い、日々の取引の利益によって、生活費等を賄っていることが、取引記録、銀行預金の記録などで明らかである場合には、事業所得の要件を満たすのではないかと思います。

事業所得となる可能性があると思われる方は、青色申告の承認を受けると損失が繰り越せたり、控除が受けられたりするというメリットがありますので、承認を受けようとする年の3月15日までに青色申告承認申請書を持って所轄税務署に相談に行かれてはいかがでしょうか。

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    The music industry in miniature .Britain’s most prestigious school of contemporary music. It teaches not only how to play a musical instrument well, but also how to interact with the industry. Among the directions — vocals, playing instruments, music business, production and songwriting (it is taught, for a moment, vocalist Lamb).

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