Aditya Vijayaraghavan and Abhinav Goel discuss the indirect tax levy on cryptocurrency in the Indian scenario and the way forward for investors and the industry
Abstract: Most widely accepted medium of exchange still happens to be in control of governments and their fiat currencies across the world. However, in recent times virtual Currencies have been in the gust of controversies globally ever since it gained popularity. There have been several attempts globally to ban cryptic virtual currencies. Despite of efforts governments across the world have failed and are now scrambling to regulate and levy tax. Regulators in India to are blowing hot and cold unable to make up their minds. This article provides insight into the origin, evolution, current status of legal position of virtual currencies in India and examines the scope of levy and implications of Goods and Services Tax (GST) in its relation.
1. INTRODUCTION
Advent of internet revolution began in 1965, for military application and later finding its way into the civilian world has drastically changed our lives[1] and how we interact on a day-to-day basis. The growing use and integration of internet has prophesied itself into this medium of mass exchange of information and consumption. In the case of financial industry, it was early 1980s, when the banks adopted the internet to provide online banking services.[2] The advent of technology, helped commerce and trade flourish. However, there was an increasing reliance on third party and financial institutions for the purposes of electronic payment.[3] The system though efficient is criticised for its cost of mediation and the difficulty inherent in a trust-based system. It was only time; a certain percentage of frauds/ lapses are unavoidable. Examples like Yes Bank loan Fraud (2020), Punjab National Bank fraud (2018), the aftermath sub-prime mortgage (2008) amongst several other financial events across the world has led to the weakening of trust in banking and financial systems.
As fate would have it, the financial institutions and the reserve banks needed change to garner trust of the society. A financial renaissance: a new currency for digital age.
This paper will delineate upon the GST implications arising out of VCs, and crypto tokens. In Part II, the paper will set the premise by elucidating the origin and evolution of blockchain and crypto tokens. Part III, shall deliberate upon the current legal position of crypto tokens in India. Part IV, shall dwell into the concepts of VCs, Smart Contracts and Non-fungible Tokens (NFT). Under Part V, this paper shall discuss the issues of classification under GST. Further, in Part VI, this paper shall evaluate plausible indirect tax implications on VCs and Crypto Token related transactions. In conclusion, this paper shall be summarised setting forth appropriate suggestions and the way forward.
2. ORIGIN AND EVOLUTION OF BLOCKCHAIN AND CRYPTO TOKENS
In this digital age of internet there have been several attempts to create an online currency secured by encryption. All advocating autonomy and reduced governmental and third-party interference. Some of the notable mentions being B-Money[4] and Bit Gold[5], however, these were not developed completely to take-over as a payment system. As the code did not tackle the problem of double spending.
It was not until the white paper published under the name of pseudonym “Satoshi Nakamoto” in November 2008 post the sub-prime mortgage crisis. The aftermath was handled by issuing glut of currency backed my nothing leading to surge in gold prices. One might argue that bitcoin was introduced with a political motive. Specially, when the message conveyed by Nakamoto in the genesis block code read "The Times 03/Jan/2009 Chancellor on brink of second bailout for banks".[6]
Notwithstanding, the world’s first successful cryptocurrency, Bitcoin, was introduced to the world in 2009. Dubbed as a work of genius on par with the Mona Lisa.[7] Started as not more than an obscure code of Peer-to-Peer Electronic Cash System[8], Bitcoin presently has the archaic reminisce of governments and central banking at its toes in the realm of regulatory uncertainty. As virtual currency (VC) and Tokens exist independently of any virtual environments, competing with fiat currencies. Primarily for the reason that cryptocurrency weeds out all these problems of central banking, governmental centralization and regulation by introducing a secure and a reliable digital currency which can sent from one person to the another without the involvement of a third party.
It has been over a decade, since the quite release of Bitcoin, the VC that setoff the frenzy of believers, buyers, traders, Hodlers and mostly legal uncertainty.
2.1. MONEY AS GOLD, PAPER AND CRYPTO TOKEN
To understand the nature of VCs it is necessary to travel back in time and briefly examine the historical evolution of currencies and fiat money. The idea of currencies or money as a medium of exchange evolves from the user preference in the social system, a system that is stable, resilient, quantifiable and easy to use. Coins made of precious metals like gold, silver etc. have been in use as early as 700 BC.[9] As a currency these coins issued by a central authority had desirability, as they had an intrinsic value primarily due to their weight and purity. As a result, the need for having a central authority is not necessary. Moreover, commodity-based currency had anonymity as there were no inbuilt mechanisms to track users or use. Generally, commodity-based currencies had maintained stability, but there have been occasions where the value fluctuations have been beyond one might call “desirable” due to factors like supply and demand.[10]
Over time, most moved to the paper-based fiat currencies what we are familiar with. Currencies decreed with a central authority as a legal tender, having no intrinsic value and are convertible into commodities at the will of the prerogative of the issuing authority.[11]
Whereas, a decentralized VCs such as Bitcoin appear far detached from the gold, a commodity often used in comparison. Inasmuch, having no physical manifestation, they have no intrinsic value, and their value is generally not backed by a government. However, in the recent times VCs have gained popularity as a store of value despite of regulatory uncertainty.
2.2. EVOLUTION OF BLOCKCHAIN TECHNOLOGY
VCs have been around well before the time of Bitcoin.[12] However, with Bitcoin a public ledger was introduced which could record all transactions ever made, effectively overcoming the problem of double spending. The public ledger itself encompasses a structure of so-called blocks; each block contains a list of transactions, as well as the hash of the previous block created for the ledger, since each block is chained to the previous one hence the name “Blockchain”. The blockchain is distributed across several computers running the protocol. Thus, allowing multiple participants to verify new transactions made block by block.
In the above regard, all identities are cryptographically generated addresses. The Blockchain acts as a ledger of transactions between these cryptographic identities. Since the blockchain has record of all past transactions it will allow transactions only when balance is available. Thus, effectively meaning that the user does not own bitcoins. Rather, a user has the right to spend the number of bitcoins that are associated with the various addresses they are able to access.
It is pertinent to note that the blockchain technology has progressed and evolved to include smart tokens, smart contracts, NFT etc. Presently, the currency aspect of blockchain only seems to be a small part of the entire system as these protocols have varying levels of authority structure and use case scenarios.
3. CURRENT LEGAL POSITION IN INDIA
In India nearly 1.5 Crore Indians are users or have invested in the crypto space.[13] However, the exact numbers are difficult to analyse owing to several factors and anonymity. The Indian Government has a very checkered history with cryptocurrency often stuck in the dichotomy whether to impose a complete ban or to legislate cryptocurrency. This is despite of acknowledging the technological innovations and potential use case of blockchain and cryptocurrency.
Starting with the announcement made by the Reserve Bank of India in the year 2018 seeking to impose a blanket ban[14] on Virtual Currencies. Year 2020 ushered in a sign of relief to the nervous investors and businesses when the Hon’ble Apex Court in a case[15] viewed that the restrictions imposed by the Reserve Bank of India (RBI) on banks and other entities in regard to the trading of virtual currency is unfair and disproportionate. Therefore, declared the restrictions to be un-viable, despite RBI exercising its powers within its competency.
Fast forward to year 2021, the government is caught in a situation mulling over its decision in greed and panic.[16] With a draft Bill titled “Banning of Cryptocurrency and Regulation of Official Digital Currency Bill, 2021” to be tabled at the parliament at one end, seeking the ban VC’s.[17] On the other, the Ministry of Corporate Affairs of the Government of India have amended the Schedule III of the Companies Act[18], 2013 requiring companies to disclose their cryptocurrency holdings and investments during financial year. Further, the RBI has recently asked banks to continue to carry out customer due diligence processes in line with regulations governing standards for Know Your Customer (KYC), Anti-Money Laundering (AML), Combating of Financing of Terrorism (CFT) and obligations of regulated entities under Prevention of Money Laundering Act, (PMLA), 2002 in addition to ensuring compliance with relevant provisions under Foreign Exchange Management Act (FEMA) for overseas remittances.[19]
Recently, the first ever parliamentary panel discussion on cryptocurrency arrived at a consensus that cryptocurrency cannot be stopped by reasonable legal means and thus, must be regulated.[20] In furtherance, sources indicate that Government of India is preparing to ban ‘private cryptocurrency’ and is mulling to launch an official digital currency. Nevertheless the Indian proposals are flagged in the parliamentary bulletin concerning the upcoming “The Cryptocurrency and Regulation of Official Digital Currency Bill, 2021.[21]
Nevertheless, to investors and businesses it is a double whammy of regulation and uncertainty before there are clear policies and regulations in place. One may consider ban of VCs with a pinch of salt as the legislative process often times is slower and sometimes obsolete till it sees light. As Blockchain has seen exponential growth and use cases beyond the comprehension of laws and regulations resulting in an untamed juggernaut.
4. UNDERSTANDING VC’S, SMART CONTRACT TOKENS AND NFT’S
Regardless, which part of the country one belongs, one fact that remains common amongst the minds of layman, lawmakers and practitioners is that cryptocurrency or blockchain mean and only consists of VCs like Bitcoin, Litecoin, etc. Unfortunate, but the reality may seem far-fetched as there are several sides to this problem of regulatory uncertainty. This subject is a juggernaut in its leaps and bounds will cover and intersect several aspects of law like tax, policy & regulation, information technology, intellectual property, property law just to name a few. However, for the sake of brevity this paper only discusses the Indirect tax implications in India.
Having regard to the above, the most important question for the purposes of understanding GST levy is to determine– “Whether, VCs, Smart Contract Tokens and NFT are a money or goods or security?” Prima facie this question is perhaps one with no clear answers and may require to be interpreted basis the underlying transaction in absence of legal clarity. However, for the sake of shining light on multi-fold tax implications, the understanding of VCs, Smart Contract Tokens and Tokens are discussed separately.
4.1. VIRTUAL CURRENCIES (VCs)
Generally, VCs based on blockchain technology could be defined as a cryptic self-regulated digital currency issued and controlled in accordance with a software code used and accepted among the members of virtual community. It must be noted that blockchain backed VCs can be coded for different purposes and can encompass services beyond mere being used as a medium of exchange.
4.2. SMART CONTRACTS
Smart Contract[22] are based on the same technology as VCs i.e. Blockchain. However, Ethereum based Smart Contract are one of the most potential use cases that can enable the transfer of everything from currency to goods and services around the world. Smart contracts offer a standardized method to accelerate data exchange and enables process between IoT devices by removing the intermediary. This would allow organisations to have a verifiable check at every stage. However, smart contracts running on Ethereum can trigger an action based on a condition without an Crypto token involved.[23] Thus, Smart Contracts may or may not necessarily involve the use of VCs for the purposes of application. Recently use of Ethereum smart contracts
for VC backed decentralized finance (DeFi) are gaining popularity. These will allow users to access to host of financial products and services like loans, trading, investment etc.[24]
4.3. NON-FUNGIBLE TOKENS (NFT)
NFTs[25] can be described as one of a kind asset. As the name suggests these cannot be replaced by another i.e. non-fungible. NFTs like VCs are a unit of data stored on a digital ledger, called a blockchain that certifies a digital asset to be unique and therefore not interchangeable. NFTs finds itself in a unique situation as it can be used represent items over which you can have ownership such as art, videos, audio, property etc. However, it must be noted that the underlying asset and conditions may vary in the case of NFTs. For example in the case of art, music, video etc. NFT may allow the creator to receive royalty on his creation upon resale or interest upon maturity inter alia others. Whereas, in the case of physical or virtual property represented by NFT may only entitle one time consideration upon sale.
5. ISSUES OF CLASSIFICATION FOR LEVY
As far as GST is concerned, the most common aspect debated is the classification of VCs for the purposes of levy. At this juncture, it is relevant to introspect the decision of the Hon’ble Apex Court Internet and Mobile Association of India v. Reserve Bank of India[26] where the court examined the nature of VCs. It observed that VCs, though not legal tender are capable of performing some or most of the functions of real currency. Therefore, the same cannot be considered as goods or commodities.
Whereas, the Indian law, cryptocurrency and its features invite different legal and tax implications. Presently, there are various regulatory gaps and implications that need to be considered in relation to cryptos. The under the 2019 draft law has attempted to define cryptocurrency or VCs as follows:
► Any information or code or number or token not being part of any Official Digital Currency;
► Generated through cryptographic means or otherwise;
► Providing a digital representation of value which is exchanged with or without consideration, with the promise or representation of having inherent value in any business activity;
► Which may involve risk of loss or an expectation of profits or income, or functions as a store of value or a unit of account, and;
► Includes its use in any financial transaction or investment, but not limited to, investment schemes.
Apropos, meaning any digital currency generated over blockchain with no official government decree, irrespective of its use case scenario as a medium of exchange or store of value. Nevertheless, the Central Economic Intelligence Bureau (CEIB) has taken a different approach to the definition and has proposed to classify VCs as an “intangible asset.” Effectively, allowing to levy 18% GST on anything, VCs.[27]
However, it must be noted that VCs are capable of assimilation into the general concepts of property, there are difficult questions as to the type of property that is involved.[28] Moreover, given the bidirectional flow of VCs, which are exchanged for traditional currencies in the context of exchange transactions should not be categorized as tangible asset. Further, treating them as supply of goods will be irregular considering VCs consist of exchange of different means of payment and hence, they constitute supply of services or goods.
At this juncture, it is pertinent to highlight that Representatives from crypto exchanges in India have approached the Authority for Advance Rulings seeking clarity on whether Bitcoin would be characterised as a “good” or a “service” for the purposes of levy.[29] Accordingly, it is necessary to determine whether VC's are goods or services, asset or security or money?
6. TRANSACTIONAL ANALYSIS AND REGULATORY CHALLENGES
In light of the above discussion, we now proceed to analyse the GST law in relation to the cryptocurrency transactions in the following scenarios:
6.1. Buying and selling crypto in Exchanges
The most common means of accessing cryptocurrency is the buying and selling cryptocurrencies over exchanges. One might find these exchanges akin to the traditional stock markets sans the presence of regulatory or any statutory regulations. Exchanges simplify the process of buying, selling and also provide a platform for trading of currencies. Usually most exchanges charge a commission for buying, selling and trading of cryptocurrencies.
The above can be illustrated as under:
Having regard to the above, the exchanges are charging a commission for the facilitation of service. The commission charged by the exchanges should be considered as a supply of service and should be taxable. However, what remains a question is whether cryptocurrencies will be treated as goods or securities?- As “securities” per se neither fall in the definition of goods nor services, they fall in the definition of “non-taxable supply” under Section 2 (78) of the CGST Act, 2017 and provisions of GST would be made applicable accordingly.
In a similar scenario, cryptocurrencies can also be traded over foreign crypto exchanges, and in most likely scenario the services of the exchange are made outside the taxable territory. This exposes this transaction to several other laws including FEMA, 1999. However, the key ingredient remains to see if the services of the foreign cryptocurrency exchange will qualify as ‘import of service’? In order to qualify as import of service following conditions need to be met:
Accordingly, the service recipient will be required to discharge IGST under Reverse Charge Mechanism under Entry 1 of Notification No. 10/2017- Integrated Tax (Rate) dated 28 June 2017 as the supplier of service is located in a non-taxable territory.
Having regard to the above, what remains to be seen is how the Indian government will treat the same subject to its reservations in respect to the latter transaction.
6.2. Peer to peer
The second scenario dealing in cryptocurrencies include peer to peer trading. Wherein, the parties buy and sell cryptocurrencies inter se without the involvement of any third party or brokerage. Usually such transactions are privately dealt at a price agreeable to the parties. The same can be illustrated as below:
In the above scenario, such transaction is similar to transaction in ‘money’. A transaction in money, per se, is outside the ambit of GST as it does not qualify the definition of goods or services. However, it is pertinent to note that any related activity, for which a separate consideration is charged, should be subject to GST if other elements of taxability are present.
6.3. Received as remuneration for goods and/or services
Cryptocurrencies in the present time is being used as a medium of exchange for goods and/or services. Similar to a scenario where one uses money as a medium of exchange. The transaction can be illustrated as under:
Apropos to the above, in a scenario where the consideration is received in the form of cryptocurrencies for the supply of underlying goods or services GST will be levied basis the applicate rate of the supplied goods or services.
6.4. Creating, Selling and Reselling of NFTs
NFTs or Non-Fungible Tokens represent ownership of unique items like images, music, videos, property etc. which are not interchangeable. They can only have one official owner at a time and are secured over blockchain.[30] Thus, NFTs may have multiple use case scenarios. Whereas, in case of artistic content some NFTs also automatically pay out royalties to their creators when sold. For the ease of understanding the transaction of NFTs can be simplified as under:
As discussed in the above transactions, GST should be leviable on commission. Further, royalty payment received by the creator is also amenable to GST. At this juncture, it is pertinent to highlight that there is also no clarity on whether NFTs are “contracts”, as per the Indian Contract Act, 1872, or whether they qualify as derivatives. If NFTs qualify as the latter they will not be a subject matter of GST. Further, we may see FEMA and import and export implications in case of buying or selling NFTs abroad.
6.5. Financial Services over DeFi.
DeFi stand for decentralised finance, based on the Ethereum blockchain. DeFi has variety of applications and projects in the public blockchain space. The smart contracts are automated enforceable agreements that do not need intermediaries to execute and can be accessed by anyone with an internet connection.[31]
DeFi allows anyone to earn interest or obtain a loan by lending or borrowing cryptocurrencies. The transaction can be understood as under:
Having regard to the above transaction, it is pertinent to note that if the Defi exchange were to charge a commission for its services in such scenario it should qualify as supply and shall be amenable to GST levy. Whereas, if cryptocurrencies are regarded as money then there shall be no GST levy as it should qualify as a transaction in money. Further, the interest income received by the lender should also be exempted vide Entry number 27 of Notification number 12/2017- Central Tax (Rate) dated 28 June 2017.As services by way of extending deposits, loans or advances in so far as the consideration is represented by way of interest or discount (other than interest involved in credit card services) are exempted.
6.6. Mining of Cryptocurrencies
Backbone of cryptocurrency is to ensure verification of transactions and there is no duplicity or fraud. This process of verification is called mining. In other words every transaction needs to be verified by miners who receive a fee to avoid delays and reward for the voluntary efforts undertaken by them. It must be noted that a transaction can also be verified without any transaction fees depending on mining difficulty.[32]
For the purposes of GST levy, it is necessary to arrive at the appropriate classification. Questions of identifying the service recipient is also indefinite and unknown for the purposes of GST levy in case of mining fees. Thus, possibly the revenue generated through mining may be treated as a self-generated Capital Asset (intangible) at the time of generation and accordingly it may not attract the GST. Questions on valuation need to be clearly specified for the valuation of such capital assets. Further, there is a need for clarity on input tax credit would be available towards mining equipment. However, it is pertinent to highlight that it may suffer the same instance of levy at the time of sale as discussed above.
7. CONCLUSION
Apropos to the chapters above, cryptocurrencies and the question of GST levy seem to be unclear. As there is no regulatory oversight. The technology surrounding VC’s are evolving faster than the laws. The governments across the world including India are tizzy on how to tackle this crypto boom. There are several challenges in the areas of identifying users i.e. KYC, Valuation challenges in case of currency conversion arbitrage, determining place of supply, whether mining as a domestic supply or export of service, issues with respect of application of reverse charge mechanism, input tax credit with respect to mining equipment just to name a few.
Whereas, the courts have emphasised that an outright ban is seldom the solution to perceived problems, and must only be a last resort. As the situation prevails it is noteworthy to appreciate the developments in the blockchain field and its applications. Nevertheless, the industry has set close eyes on the developments of the 2021 bill during the winter session of the parliament.
About Authors
Disclaimer: For discussion purpose only. This material has been prepared for general informational purposes only and the views expressed are that of the Authors. In case you require further information or assistance in respect of your business, please feel free to contact us.
REFERENCES
[1] Alaa Gharbawi, Revolution of the Internet (1991). [2] Evan Sparks, Nine Young Bankers Who Changed America: Thomas Sudman ABA BANKING JOURNAL (June 26, 2017.) https://bankingjournal.aba.com/2017/06/nine-young-bankers-who-changed-america-thomas-sudman/ [3] N. Krishna Veni, Introduction to E-Commerce, E-Business & E-Banking (2007). http://www.indianmba.com/faculty_column/fc545/fc545.html [4] Wei Dai, B-Money (1998). http://www.weidai.com/bmoney.txt [5] Nick Szabo, Bit Gold. (December 2005). https://unenumerated.blogspot.in/2005/12/bit-gold.html [6] Benjamin Sherry What is the Genesis Block in Bitcoin Terms? (January 2, 2018). https://www.investopedia.com/news/what-genesis-block-bitcoin-terms/ [7] Ari Altstedter, Bitcoins Create Truly Democratic Policy, Followers Say, CANADA.COM (Jul. 22, 2011). [8] Satoshi Nakamoto, Bitcoin: A Peer-to-Peer Electronic Cash System (Nov. 2008). https://bitcoin.org/bitcoin.pdf [9] PETER L. BERNSTEIN, THE POWER OF GOLD: THE HISTORY OF AN OBSESSION, 24 (Hoboken, N.J.: Wiley And Sons, Inc.) (2004). [10]JEFFRY A. FRIEDEN, GLOBAL CAPITALISM: ITS FALL AND RISE IN THE TWENTIETH CENTURY, (New York: W. W. Norton and Company) (2006). [11] Benjamin J. Cohen, The Geography of Money, Ithaca, N.Y.: Cornell University Press, 1998 [12] Supra note 4 & 5. [13]Koustav Das, RBI’s clarification on cryptocurrency: What it means for investors in India, INDIA TODAY, 1 June 01, 2021. https://www.indiatoday.in/business/story/rbi-s-clarification-on-cryptocurrency-what-it-means-for-cryptocurrency-trade-in-india-1809419-2021-06-01 [14] Reserve Bank of India, Statement on Developmental and Regulatory Policies (April 05, 2018). https://rbi.org.in/scripts/BS_PressReleaseDisplay.aspx?prid=43574 [15] Internet and Mobile Association of India v. Reserve Bank of India, 2020 (3) TMI 364. [16] Sandeep Soni, Bitcoin Alert! Govt says crypto gains taxable as income, GST applicable on services by crypto exchanges, FINANCIAL EXPRESS, March 28, 2021. https://www.financialexpress.com/market/bitcoin-alert-govt-says-crypto-gains-taxable-as-income-gst-applicable-on-services-by-crypto-exchanges/2222192/ [17] Prachee Mishra & Anurag Vaishnav, Legislative Brief: The Draft Banning of Cryptocurrency and Regulation of Official Digital Currency Bill, 2019, PRS LEGISLATIVE RESEARCH (December 18, 2019); Surjoit Gupta, Winter session: Government to move bill to prohibit all private cryptocurrencies, TIMES OF INDIA, November 23, 2021 http://timesofindia.indiatimes.com/articleshow/87873625.cms?utm_source=contentofinterest&utm_medium=text&utm_campaign=cppst [18] Ministry of Corporate Affairs, Notification No. G.S.R. 207(E) (March 24, 2021). [19]Reserve Bank of India, Customer Due Diligence for transactions in Virtual Currencies (VC), RBI/2021-22/45 DOR. AML.REC 18 /14.01.001/2021-22 (May 31, 2021). [20] Nikita Prasad, Crypto Bill To Be Introduced In Winter Session: What You Need To Know, NDTV PROFIT, November 23, 2021 (https://www.ndtv.com/business/cryptocurrency-bill-government-to-introduce-official-cryptocurrency-bill-in-current-winter-session-of-parliament-2622015) [21] Supra note at 17. [22] ETHEREUM, https://ethereum.org/en/whitepaper/ [23] Lucas Mearian, What's a smart contract (and how does it work)?, COMPUTER WORLD (July 29, 2019), https://www.computerworld.com/article/3412140/whats-a-smart-contract-and-how-does-it-work.html [24] Supra note 22 at https://ethereum.org/en/defi/ [25]Id. at https://ethereum.org/en/nft/ [26] Supra note 14. [27] BusinessToday.in, Centre may impose 18% GST on bitcoin trading, Business Today, December 29, 2020 (https://www.businesstoday.in/latest/economy-politics/story/centre-may-impose-18-percent-gst-on-bitcoin-trading-282951-2020-12-29) [28] Quoine Pte Ltd v. B2C2 Ltd, [2020] SGCA (I) 02. [29] Suprita Anupam, Cryptocurrency: Bitcoin Exchanges To Approach AAR Over GST, INC42 (January 5, 2018) at https://inc42.com/buzz/cryptocurrency-bitcoin-exchanges-aar-gst/ [30] Supra note 22 [31] Hedera, What is decentralized finance (DeFi)? https://hedera.com/learning/what-is-decentralized-finance?gclid=Cj0KCQiAq7COBhC2ARIsANsPATHFIzrH-ZVDULqp5eY6qZkHSuJISUw3tGg8HACtsJERi_XPMijl5dcaAoPKEALw_wcB (Last updated 29 December 2021). [32] Jake Frankenfield, CRYPTOCURRENCY DIFFICULTY, (July 26, 2021), https://www.investopedia.com/terms/d/difficulty-cryptocurrencies.as
コメント