South Korean Bitcoin Holder Taxed for Routing Funds Through Spouse’s Account Wins Reinvestigation

South Korea has enforced its virtual-asset Travel Rule since March 2022, requiring the exchange of sender and recipient identity information for transfers exceeding 1 million won. This makes it difficult to transfer assets directly from a self-custodied Ledger cold wallet to a domestic exchange. The case concerns whether tax authorities may deem assets a gift based solely on their movement through a spouse’s account, and how control of private keys, written agreements and beneficial ownership should be proven.

From July to October 2021, a man seeking to buy a home transferred 67 of his 80 bitcoins back to South Korea through his spouse’s account at an overseas exchange. The bitcoins remained in the account for just 2–8 minutes. He separately gave the other 13 bitcoins to his spouse. The Seoul Jamsil District Tax Office imposed gift tax, but South Korea’s Tax Tribunal ruled on June 4, 2026, that the investigation was insufficient and ordered the authorities to determine who controlled the Ledger hardware wallet before issuing a new assessment.