Transactions in cryptocurrencies
1) Are individuals taxed on gains on the sale of cryptocurrencies?
When an individual acts as an investor, any capital gain on the sale of cryptocurrencies realised by 31 December 2025 will be liable to a 26 per cent substitute tax. The Italian Budget Law 20251 has increased to 33 per cent the substitute tax rate for any capital gain realised from 1 January 2026.
The capital gain taxable base is equal to any positive difference between the consideration received, or the fair market value of the cryptoassets exchanged, and their cost or purchase price. However, if more favourable, for 2025 crypto holders can opt for the payment of a substitute tax of 18 per cent2 on the fair market value of the cryptocurrencies held at the beginning of relevant tax period, instead of the ordinary capital gain taxation.
Any capital loss can be offset against the capital gains realised in the same fiscal year. If losses exceed gains, they can be carried forward in the subsequent four years. In absence of a specific provision, capital losses realised under the 26 per cent substitute tax regime should be carried forward in the subsequent four years to offset any capital gain realised under the 33 per cent substitute tax regime.
When an individual acts as a trader subject to the individual business income tax regime, any gain on the sale of cryptocurrencies will be subject to the applicable progressive personal income tax rates ranging from 23 per cent to 43 per cent.
1See Art. 1, par. 24 of Italian Budget Law 2025.
2To be paid by 30 November 2025 or in a maximum of three annual instalments from that date (last two instalments to be increased by applicable interest).
2) Is cryptocurrency subject to yearly mark-to-market valuation?
Where, based on the position of the Italian Tax Authority, cryptocurrencies are regarded as “foreign currency”, Italian GAAP requires taxpayers to value such “currency” at their fair market value at the end of the fiscal year and report any exchange gains/losses in the profit and loss account.
3) Are corporates taxed on gains on the sale of cryptocurrencies?
According to the interpretation of the Italian Tax Authority, any gains on the sale of cryptocurrencies should be included in the taxable base for Italian corporate income tax purposes. Any tax loss may be offset against gains realised in the same fiscal year. If the tax losses exceed gains, they can be carried forward in subsequent years, subject to a limit of 80 per cent of the related income.
4) Is payment for goods/services in cryptocurrencies a taxable event?
Yes. In principle, the use of cryptocurrency for the purchase goods/services may trigger a capital gain equal to the fair value of the exchanged cryptocurrency (i.e. the value of the good/service purchased) and the cost or purchase price of the cryptocurrency itself.
5) What is the tax treatment of cryptocurrencies received from mining?
According to the interpretation of the Italian Tax Authority, the fair market value of cryptocurrencies received from mining would be regarded as income from capital and would be subject to the 26 per cent substitute tax. According to certain interpretations, the increase in the substitute tax rate to 33 per cent also applies in this case with reference to capital gains realised since 1 January 2026.
For corporate entities, cryptocurrencies received from mining should be subject to 24 per cent corporate tax on their market value upon receipt.
6) What is the tax treatment of cryptocurrencies received by airdrop?
There is no official interpretation on cryptocurrencies received by airdrop. No taxation would take place at the time the individual receives the cryptocurrencies.
For corporates, although there is no official interpretation, they should be subject to 24 per cent corporate tax on their market value upon receipt.
7) What is the tax treatment of cryptocurrency received from staking?
As to the tax treatment of the cryptocurrencies received from staking, the Italian tax authority has issued directions stating that cryptocurrencies received may be regarded as income from capital (at their value on the day the individual receives such income) and would be subject to the 26 per cent substitute tax.
According to certain interpretations, the increase in the substitute tax rate to 33 per cent also applies in this case with reference to any income from capital received since 1 January 2026.
For corporates, although there is no official interpretation, they should be subject to 24 per cent corporate tax on their market value upon receipt.
8) What is the tax treatment of the lending of cryptocurrencies?
There is no official interpretation on lending of cryptocurrencies.
Cryptocurrency received as interest may be included in the individual taxable base (at its value on the day the individual receives such interest) and would be subject to the applicable progressive rates from 23 per cent to 43 per cent.
For corporates, although there is no official interpretation, they should be subject to 24 per cent corporate tax on their market value upon receipt.
9) What is the tax treatment of a hard fork?
There is no official interpretation on the tax treatment of a hard fork. However, according to some commentaries, the expectation is that a hard fork should benefit from tax-deferral where an individual acts as an investor. In other cases, including corporates, it is likely to result in a taxable transaction.
10) What is the tax treatment of employee salary in cryptocurrency?
No specific tax treatment should apply.
Employees should be liable, in respect of the value of the cryptocurrencies on the date of their receipt, to the progressive income tax rates from 23 per cent to 43 per cent, plus social security contributions. The employer should proceed with its withholding tax obligation on the basis of the market value of the cryptocurrencies upon payment.
11) How are gifts of cryptocurrency taxed, including in-game rewards?
No income taxation should take place at the time the individual receives the cryptocurrencies in cases when the individual does not act as trader or in his/her capacity of employee.
The value of the cryptocurrencies may be included in the taxable basis of inheritance and gift duties (at its value on the day the individual receives it).
12) Is there a tax-deferral when exchanging cryptocurrency/assets?
The exchange of cryptocurrencies for other cryptocurrencies having the same characteristics and functions does not represent a taxable event.
13) Is there any transfer tax on the acquisition of cryptocurrencies?
No.
14) Is there obligations to declare cryptocurrency to tax authorities?
Yes. Individuals must declare, annually upon filing of their tax return the Euro value of any cryptocurrency held at 31 December for each fiscal year. In the absence of such declaration, a penalty of 3 per cent to 15 per cent of the value of cryptocurrencies applies. However, where the declaration is filed later than 90 days after expiry of the time limit, a flat penalty of €258 applies.
15) Are there reporting obligations for cryptocurrency transactions?
No specific reporting obligations, other than the inclusion in the annual tax filing.
The EU Council has adopted a directive amending EU rules on administrative cooperation dealing with the reporting and automatic exchange of information in relation to transactions in crypto-assets (DAC8). DAC8 imposes new tax transparency rules for all service providers facilitating transactions in crypto-assets for customers resident in the EU. The rules, which will come into effect in 2026, will require all service providers, of whatever size and wherever located, to report on crypto-asset transactions carried out by clients residing in the EU.
16) How are cryptocurrency transactions treated for VAT purposes?
According to CJEU and the interpretation of the Italian Tax Authority, they should be treated as VAT exempt supplies.
Initial Coin Offerings
17) What is the tax treatment of Initial Coin Offerings for issuers?
According to the interpretation of the Italian Tax Authority, the issuance of ICOs in the form of utility tokens does not constitute a taxable event. Corporate income tax will be due on the income deriving from the supply of good or services related to the token. There is no official interpretation of the tax treatment of security tokens.
18) What is the VAT treatment of ICOs, including rules on vouchers?
According to the interpretation of the Italian Tax Authority, ICOs are subject to the same VAT treatment applicable to vouchers. As a consequence, the issuance of tokens under an ICO is not relevant for VAT purposes and any VAT will be due upon the utilisation of the token.
19) Are ICOs liable to any stamp duty?
No.
Transactions in NFTs
20) What is the tax treatment for individuals of the creation of NFTs?
No taxes are due upon creation of NFTs. The costs to create the NFT should be computed in the taxable basis of the creator qualifying as a professional.
21) What is the tax treatment for corporates of the creation of NFTs?
No taxes are due upon creation of NFTs. The costs to create the NFT should be computed in the taxable basis of the creator.
22) Are NFTs taxed differently to cryptocurrencies?
The treatment of NFTs for Italian tax purposes is still uncertain and currently there are no rules stating that NFTs are deemed to represent any underlying assets.
However, it would be reasonable to believe that the tax treatment for individuals will depend on the nature of the underlying assets (e.g. in case the underlying asset is a work of art the income from the economic utilisation by the author will be subject to the applicable progressive rates from 23 per cent to 43 per cent).
For corporates, any gains on the sale of NFTs should be included in the taxable base for Italian corporate income tax purposes. Any tax loss may be offset against gains realised in the same fiscal year. If the tax losses exceed gains, they can be carried forward in the subsequent years, subject to a limit of 80 per cent of the related income.
23) Can tax be deferred when exchanging NFTs for other NFTs/crypto?
According to the interpretation of Italian Tax Authority (i) the exchange of NFTs for other NFTs is not a taxable event, while (ii) the exchange of cryptocurrencies for NFTs is a taxable event.
24) What is the tax treatment of gifted NFTs (incl. in-game rewards)?
No income taxation should take place at the time an individual receives the NFTs, in cases where the individual does not act as a trader or in his/her capacity as an employee.
The value of NFTs may be included in the taxable basis of inheritance and gift duties (at its value on the day the individual receives it).
25) Is there any transfer tax when acquiring NFTs for consideration?
No.
26) Is it obligatory to declare a holding of NFTs to tax authorities?
Although the treatment of NFTs for Italian tax purposes is still uncertain, there is no obligation to declare to tax authorities the holding of NFTs.
27) Are there tax reporting obligations specific to NFT transactions?
No.
28) How are transactions in NFTs treated for VAT purposes?
Currently there are no specific VAT rules regarding NFTs. However, transaction in NFTs would most likely be treated as digital services for VAT purposes.
Want to know more about cryptoassets and tax?
We also have guides and FAQs on how cryptocurrencies and NFTs are taxed differently in other European jurisdictions. You can view them online or download them as a single guide using the links below.
This document (and any information accessed through links in this document) is provided for information purposes only and does not constitute legal advice. Professional legal advice should be obtained before taking or refraining from any action as a result of the contents of this document.
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