Italy Crypto Tax

Asset Classification Table

| Asset Type | Classification | Tax Treatment | |---|---|---| | Cryptocurrencies (BTC, ETH, SOL, etc.) | Cripto-attività | 26% imposta sostitutiva on gains | | Utility tokens | Cripto-attività | 26% imposta sostitutiva on gains | | Security / financial tokens | Cripto-attività (unless qualifying as traditional securities) | 26% imposta sostitutiva; if traditional security, standard financial income rules | | Stablecoins (non-euro, e.g. USDT, USDC) | Cripto-attività | 26% imposta sostitutiva on gains | | Euro e-money tokens (MiCAR-compliant) | Cripto-attività (special sub-class) | 26% from 2025; remains 26% from 2026 (exempted from 33% increase per L. 199/2025) | | NFTs | Cripto-attività | Same 26% regime; creation and sale by artist = business income |

Taxable Events Table

| Event | Taxable? | Notes | |---|---|---| | Crypto → fiat (sell) | Yes | Gain = proceeds − cost basis | | Crypto → crypto (swap) | Yes | Each swap is a disposal at FMV | | Crypto → goods/services | Yes | Disposal at FMV of goods/services received | | Receiving crypto as payment | Yes | Income at FMV when received | | Transfer between own wallets | No | No change in beneficial ownership | | Wrapping/unwrapping (ETH → WETH) | Depends | Generally not taxable if no economic change; conservative: taxable | | Hard fork (receiving new coin) | Not a taxable event on receipt | Cost basis = €0; taxable on disposal |

Legal basis

D.Lgs. 461/1997, Arts. 5--7, applied to Art. 67(1)(c-sexies) TUIR.D.Lgs. 461/1997, Arts. 5--7

Rate Table

| Tax Year | Rate | De Minimis Exemption | Citation | |---|---|---|---| | 2023--2024 | 26% | First €2,000 of gains exempt | L. 197/2022, Art. 1 c. 126 | | **2025** | **26%** | **None (abolished)** | L. 207/2024, Art. 1 c. 23 | | 2026 onwards | 33% (general); 26% (euro e-money tokens) | None | L. 207/2024, Art. 1 c. 24; L. 199/2025 |

Computation formula

Net gain = Σ(disposal proceeds − cost basis) for all crypto disposals in the year Tax due = Net gain × 26%L. 207/2024, Art. 1 c. 23

Net loss result

If net result is a loss, no tax is due and the loss can be carried forward (see Section 8).

Legal basis

D.L. 201/2011, Art. 19 c. 18, as amended by L. 197/2022, Art. 1 c. 146.D.L. 201/2011, Art. 19 c. 18; L. 197/2022, Art. 1 c. 146

IVCA Parameters Table

| Parameter | Value | |---|---| | Rate | 0.2% per annum (2 per mille) | | Taxable base | Market value of all crypto holdings as at 31 December | | Pro-rata | If held for part of year, proportional to days held / 365 | | Minimum threshold | IVCA not due if calculated amount < €12 | | Who pays | Italian tax residents holding crypto anywhere (self-custody, foreign exchanges, etc.) | | Exemption | Not due if held via Italian intermediary that applies and withholds the equivalent stamp duty (imposta di bollo) | | Payment | Via Modello F24, codes 1727 (tax), 1728 (interest), 1729 (penalties) |

Legal basis and revaluation rule

L. 207/2024, Art. 1 cc. 26--29. Taxpayers may elect to revalue the cost basis of crypto held as at 1 January 2025 to fair market value on that date, by paying an 18% substitute tax on the revalued amount. This replaces the previous 14% revaluation option for holdings at 1 January 2023 (L. 197/2022).L. 207/2024, Art. 1 cc. 26--29

Revaluation Parameters Table

| Parameter | Value | |---|---| | Reference date | 1 January 2025 | | Substitute tax rate | 18% of FMV at reference date | | Payment deadline | 30 November 2025 (or in up to 3 equal annual instalments from 30 November 2025) | | Interest on instalments | 3% per annum on 2nd and 3rd instalments | | Effect | New cost basis = FMV at 1 January 2025 for future disposals |

Cost Basis Methods Table

| Method | Status | Notes | |---|---|---| | LIFO (Last In, First Out) | **Default** under Art. 67(1-bis) TUIR for financial assets | Standard method for Italian tax purposes | | Specific identification | Acceptable if clearly documented | Must be consistently applied | | Average cost | Not standard for Italian tax purposes | Not recommended | | FIFO | Not the default | May be used if declared and consistently applied |

Cost basis includes

Purchase price in EUR (converted at ECB rate on transaction date); Exchange/trading fees and commissions; Network/gas fees directly attributable to the acquisition; Any substitute tax paid for revaluation (added to revalued basis)

DeFi/Staking/Mining/Airdrops Table

| Activity | Tax Treatment | Timing | Notes | |---|---|---|---| | Mining (private, occasional) | Income at FMV when received (redditi diversi) | At receipt | If habitual → business income (reddito d'impresa) | | Mining (business/commercial) | Business income (partita IVA required) | At receipt | Subject to IRPEF + IRAP + social contributions | | Staking rewards | Income at FMV when received | At receipt | Cost basis of received tokens = FMV at receipt | | DeFi lending interest | Income at FMV when received | At receipt | Treated as redditi diversi | | Liquidity provision | Adding to pool = potential disposal; LP tokens = new acquisition | At each event | Impermanent loss: no specific guidance; conservative = non-deductible | | Airdrops (gratuitous) | Taxable at FMV when received if linked to any economic activity | At receipt | Purely unsolicited airdrops may have €0 cost basis → full gain on disposal | | Airdrops (service-related) | Income at FMV when received | At receipt | E.g. rewards for testing, referrals | | Yield farming | Income at FMV when received | At receipt | Each token receipt is a taxable moment |

NFT Treatment Table

| Scenario | Treatment | |---|---| | Purchase of NFT | Acquisition at cost — cost basis for future disposal | | Sale of NFT for profit | Capital gain taxed at 26% (2025); same regime as other cripto-attività | | Creation and sale (artist/creator) | Business income if habitual (reddito d'impresa or reddito di lavoro autonomo); occasional = redditi diversi | | NFT → NFT swap | Taxable event — each side valued at FMV | | NFT royalties (smart contract) | Income at FMV when received | | VAT on NFT sales | Electronically supplied service — standard VAT rate (22%) may apply on B2C within EU |

Modello Redditi PF Reporting Table

| Form Section | Purpose | Who Must File | |---|---|---| | **Quadro RT, Sezione V** | Report capital gains and losses from cripto-attività | Anyone who disposed of crypto during the year | | **Quadro RW** | Monitor all crypto holdings (foreign and domestic, including self-custody wallets) | All Italian residents holding crypto at any point during the year | | **Quadro RW — IVCA section** | Calculate and declare IVCA (0.2% wealth tax) | All Italian residents with crypto holdings as at 31 December | | **Quadro RL** | Report other crypto income (staking, mining, airdrops) if classified as redditi diversi | Those receiving crypto income not classified as capital gains |

Filing Deadlines Table

| Filing Method | Deadline | |---|---| | Electronic (via Agenzia delle Entrate) | **31 October** of the following year | | Paper (via Poste Italiane, limited eligibility) | **30 June** of the following year | | Late filing (within 90 days) | Valid but subject to penalties | | Late filing (>90 days) | Considered omitted — penalties + tax collection |

IVCA Payment Table

| Method | Detail | |---|---| | Payment vehicle | Modello F24 | | Code | 1727 (IVCA tax), 1728 (interest), 1729 (penalties) | | Deadline | Same as balance due for Modello Redditi PF (30 June, or 31 July with 0.4% surcharge) |

DAC8/CARF reporting

From 1 January 2026, crypto-asset service providers (CASPs) licensed under MiCA operating in the EU are required to automatically report Italian clients' transaction data to the Agenzia delle Entrate under the DAC8 Directive (EU) 2023/2226 and the OECD CARF framework. This means the Italian tax authority will receive independent data to cross-reference against taxpayer declarations.DAC8 Directive (EU) 2023/2226; OECD CARF framework

Legal basis

D.Lgs. 461/1997, Art. 68(5), applied to cripto-attività.D.Lgs. 461/1997, Art. 68(5)

Loss Offset and Carry-Forward Table

| Rule | Detail | |---|---| | Netting within year | Crypto losses offset crypto gains within the same tax year | | Cross-asset netting | From 2025 (Redditi PF 2025), crypto losses can offset gains from other financial assets in the same imposta sostitutiva regime (Art. 67 TUIR) | | Carry-forward | Net crypto losses can be carried forward for **4 years** | | Carry-back | Not permitted | | Documentation | Losses must be properly declared in Quadro RT to be carried forward | | Losses from revaluation | If revaluation substitute tax was paid and asset is subsequently sold at a loss, the revalued amount is the cost basis |

Anti-Avoidance Rules Table

| Rule | Description | |---|---| | Abuse of law (Art. 10-bis L. 212/2000) | General anti-avoidance principle applies to crypto transactions lacking economic substance | | Controlled Foreign Company (CFC) | If crypto is held through a CFC in a low-tax jurisdiction, CFC rules may attribute income to the Italian resident | | Transfer pricing | Applicable if crypto transactions occur between related parties or entities | | Exit tax | Italian residents moving abroad may trigger exit taxation on unrealised crypto gains (Art. 166 TUIR) | | Beneficial ownership | Agenzia delle Entrate may look through nominee arrangements | | Wash sale | No specific anti-wash-sale rule, but abuse of law principle could apply to artificial loss generation |