The Court of Justice of the European Union, in its judgment of 05/03/2026 (case C-472/24, MB Žaidimų valiuta), clarifies the scope of its Hedqvist doctrine (case C-264/14, 22/10/2015) on the VAT exemption for transactions in non-traditional currencies (article 135(1)(e) of Directive 2006/112/EC). That doctrine requires two cumulative conditions: (i) that the currency has been accepted by the parties to a transaction as an alternative to legal means of payment; and (ii) that it has no purpose other than as a means of payment. The currency of an online video game does not meet those conditions, according to the Court and subject to the checks of the referring court: it serves only within the game and is not accepted outside it as a means of payment for real goods or services. The transaction is not exempt. And since the Court also rules out that the currency is a voucher, in particular a multi-purpose voucher, under article 30a of the Directive (it characterises it as an electronic service), the taxable amount is the full consideration (article 73) and not the margin between purchase and sale price.
The practical consequence affects operators of digital platforms, video games and issuers of utility tokens (digital units usable only within a specific platform) with customers established in Spain. It is advisable to review the VAT characterisation of the exchange transactions they manage, as well as the passing on of VAT to the end user. In our view, the reasoning can be extended to other digital units confined to a platform, although the judgment rules only on the currency of an online video game.
Full analysis in → The CJEU clarifies the VAT treatment of the exchange between a video-game virtual currency and traditional currencies
https://spanishtaxjournal.com/en/2026/04-28/nota-cjeu-virtual-currency-video-game/