wiki / tax & investments / Crypto Taxation by Country

Crypto Taxation by Country

Concept

Crypto taxation is determined primarily by the owner's tax residency. Where the exchange is registered and where the private keys are stored play almost no role for tax purposes—what matters is the country where you are a tax resident. Therefore, talk of "countries with no crypto tax" only makes sense together with the question of whether you can become an actual tax resident there.

Simply having a foreign address or formally renouncing your previous residency does not eliminate tax: most countries tax residents on their worldwide income. First comes relocation and change of residency, and only then—zero rate.

Three Models

Broadly speaking, countries are divided by how they view capital appreciation of crypto held by individuals.

  • Zero tax on capital gains for individuals: UAE, Singapore, Cayman Islands, Bermuda, Monaco, and a number of Caribbean jurisdictions—there is no capital gains tax as such here.
  • Holding-period exemption: Germany does not tax appreciation if the asset was held for more than one year; Portugal exempts gains on assets held longer than 365 days, while taxing short-term trades at 28%.
  • Full taxation as property or income: the US taxes crypto as property with capital gains tax; most EU countries and the UK levy capital gains or income tax at standard rates.

UAE and Singapore

The UAE remains the showcase for the zero-tax regime: for individuals there is neither income tax nor capital gains tax, and in Dubai's free zones (VARA), Abu Dhabi (ADGM), and Ras Al Khaimah, infrastructure has been built for crypto business. Singapore does not levy capital gains tax at all, so a one-off sale of crypto by a private investor is usually not taxed—however, systematic trading may be recognized as business income and fall under income tax.

Germany and Portugal

Europe offers more nuanced structures. In Germany, gains on crypto held for more than twelve months are fully exempt; when sold within a year, the personal rate applies with a small annual exemption threshold (Freigrenze) of around €1,000 (the threshold was raised from 2024). Portugal, after the 2023 reform, taxes short-term trades at 28%, maintains a zero rate for assets held longer than one year, and does not consider crypto-to-crypto exchanges a taxable event.

USA: Crypto as Property

The US treats crypto as property in the tax sense (IRS, Notice 2014-21). The practical consequence is simple: almost any disposal becomes a taxable event—sale for dollars, exchange of one coin for another, payment for a purchase with crypto. At each such event, a gain or loss is calculated relative to the acquisition cost. Gains on assets held for less than one year are taxed at ordinary income tax rates (up to 37%), while those held longer than one year are taxed at preferential long-term capital gains rates of 0/15/20%.

Staking, mining, and airdrops in the US are considered ordinary income at fair market value at the time of receipt, and later, upon sale, capital gain is added—the same token passes through two taxes. Reporting is tightening: from 2025, brokers file a new form 1099-DA with the client's gross proceeds (the first forms arrive in early 2026), and from 2026 transactions, the tax basis will also be added. The US is not yet participating in CARF—only an intention to join exchanges from 2029 has been announced (more details in the CRS overview), so for Americans, the exit tax on a change of residency becomes no less important a topic than the capital gains rate.

United Kingdom, Italy, and France

The UK taxes asset disposals: sale, crypto-to-crypto exchange, payment for goods, and gifts (except to a spouse)—these are disposals on which HMRC calculates capital gains. In 2025/26, the rate is 18% for basic-rate taxpayers and 24% for higher-rate taxpayers and applies to amounts above the annual tax-free allowance of £3,000—over several years it has shrunk from £12,300, so almost any significant gain is taxed. The basis is determined by the share pooling rule, and losses are carried forward to future periods.

Italy, from January 1, 2026, raised the rate from 26% to 33% and abolished the previous exemption threshold of €2,000—tax is calculated from the first euro; for gains on euro-stablecoins, a separate 26% regime is preserved, and as an alternative, an optional substitute tax of 18% on the value of assets as of January 1 is available (a kind of step-up). France maintains a flat tax (PFU) of 30%—12.8% income tax and 17.2% social contributions—on withdrawal to fiat, does not tax crypto-to-crypto exchanges before sale, and moves systematic trading to a progressive scale. The variation across Europe is so great that the question of tax residency matters more than the choice of exchange.

Staking, DeFi, and Airdrops

The most complex aspect of crypto taxation is correctly classifying flows. Staking rewards, lending interest, airdrops, and mining income are treated by most countries as ordinary income at the value at the time of receipt, separate from future capital gain upon sale. Portugal taxes such passive income (Category E) at 28% already at the time of crediting, the US at the ordinary rate, and almost everywhere subsequent disposal of the same token also creates appreciation. DeFi operations—exchange in a liquidity pool, wrapping, transfers between protocols—are often also considered disposals that the owner does not notice. The same careful tracking of values will also be needed when transferring crypto by inheritance.

Trend and Transparency

The trend of recent years is the closure of exemptions. Countries previously famous for zero crypto tax are gradually introducing taxes and aligning rules with international standards. Simultaneously, from 2026, CARF is being rolled out—a framework for automatic exchange of tax information on crypto assets, analogous to CRS for bank accounts. Exchanges and custodians will begin transmitting client data to their countries of residence, and quiet ownership of crypto abroad loses its point.

The specifics of this transparency are already laid out by dates. In the EU, CARF is being implemented through directive DAC8: member states will transpose it into national law by December 31, 2025, the rules take effect from January 1, 2026, and the first automatic exchange of data for 2026 will take place by September 30, 2027. In the first wave of CARF—52 jurisdictions, including the UK; in total, more than 70 countries have announced their intention to exchange, and the US plans to join exchanges only from 2029. The mechanics repeat CRS: the exchange collects data on the client's tax residency and transmits information about their balances and transactions to the country of residence.

In parallel, the EU has closed the regulatory loop: MiCA has been in effect for CASPs since December 30, 2024, and existing players have been given transitional grandfathering until July 1, 2026. It is precisely licensed providers with their AML/KYC procedures that become the point through which information goes to tax authorities. Anonymous ownership of crypto "somewhere abroad" practically no longer exists: what matters is the jurisdiction in which you actually became a tax resident, while the geography of the exchange recedes to the background.

This material is an expert overview and is not individual tax advice; rates and thresholds change, and specific situations should be verified against the current legislation of the country.


Sources

Contact information

If you have questions or need a consultation, our experts will be glad to help.

Request a callback

Related