The Italian Inland Revenue (Agenzia delle Entrate), through resolution of September 2016240, on the basis of the judgement of the EU Court of Justice (Case C-264/14), stated that operations in cryptocurrencies in exchange for fiat currencies (and vice versa) have to be qualified as "services with consideration" concerning currency, banknotes and coins used as legal tender, which fall within the exemptions provided for by the Italian Code on VAT (and, on the opposite, they may be subject to corporate tax).
It is, however, worth considering that the Court of Verona and the Italian Inland Revenue have never used the expressions "initial coin offering", "token sale" or similars and the cases they examined did not relate to a traditional sale of tokens issued in the context of an initial coin offering.
