Crypto Tax by Country: UK, US, Germany and CARF Rules

In the UK, HMRC treats selling tokens, exchanging them for another cryptoasset, using them to pay for goods or services and giving them away as disposals; gifts to a spouse, civil partner or charity are treated differently. You add each purchase to a pool per token type and deduct a proportion of the pooled cost when you dispose. Tokens bought on the same day as a sale of the same type, or within 30 days of it, follow separate matching rules. Gains are totalled for the tax year from 6 April to 5 April and reported if they exceed the Capital Gains Tax allowance, through Self Assessment or the real-time Capital Gains Tax service.

Example from HMRC: 100 tokens bought at £2 and 300 at £1 make a pool of 400 tokens costing £500, or £1.25 each. Selling 200 tokens gives a deductible cost of £250.

In the US, the IRS treats digital assets as property, not currency. Receiving crypto as payment for goods or services, as a reward, or from mining or staking is income; disposing of it for another digital asset, for dollars or for goods and services is a taxable disposal. Form 1040 includes a yes-or-no question on whether you received or disposed of digital assets during the year.

In Germany, the Federal Ministry of Finance (BMF) letter of 6 March 2025 sets out how specific crypto-assets are treated for income tax, including private disposals within one year of acquisition and other income categories.

Example: a client pays you in tokens worth EUR 1,000 when you receive them. Later you sell those tokens for EUR 1,080. Keep two records: the receipt of EUR 1,000 (the IRS, for example, treats crypto received for services as income) and the sale for EUR 1,080 with its own cost and fees.

The applicable law decides when income arises, which currency you report in, how you value the tokens and which acquisition the sale is matched with. If you already held the same token, the UK pooling rule, for example, mixes the new units with the old ones. Keep transaction IDs and the valuation source for each row instead of rebuilding the history from your final bank withdrawal.

DAC8 is the EU directive based on the OECD’s Crypto-Asset Reporting Framework (CARF). DAC8 applies from 1 Jan 2026, and 2026 is the first reporting year: crypto-asset service providers collect data on reportable transactions from that date. Information on users resident in other EU countries is exchanged within nine months of the reporting year, so for 2026 by 30 Sep 2027.

Providers report identification details for themselves and for you, and, for each crypto-asset, the aggregate gross amount paid or received for acquisitions and disposals and the aggregate fair market value of transfers. Outside the EU, the OECD lists CARF first-exchange commitments for 2027, 2028 or 2029, depending on the jurisdiction (as checked on 9 Sep 2026); the provider’s own reporting notice says which national rules and reporting year apply to your account.

Gross amounts are proceeds, not profit. Example: selling an asset for EUR 1,000 that you bought for EUR 900 shows EUR 1,000 of proceeds, while the difference is EUR 100 before fees and other adjustments. Provider reporting also sits apart from authorization: a reporting notice tells you nothing about whether the provider is licensed under MiCA, and a MiCA licence says nothing about your tax.

For every entry, keep the date, time and time zone, the asset and network, the quantity, the account or wallet, the counterparty, the type of event and the transaction ID. Add the original acquisition date and cost, the valuation currency, the price source and method, the proceeds and the fees together with the asset used to pay them. Keep the exchange export, invoice or receipt behind each line.

Example: an asset with an attributable cost of EUR 80 is sold for EUR 100 with a EUR 2 selling fee. Where the rules allow the fee as a cost, as HMRC does for transaction fees, the gain is EUR 18, not EUR 100. Mark missing history as missing rather than estimating a cost.

The IRS asks you to keep records of every purchase, receipt, sale, exchange or other disposal, and the fair market value in US dollars of digital assets received as income. HMRC asks for separate records per pool: token type, disposal date, number disposed of and remaining, value in pounds sterling, bank statements and the pooled cost before and after each disposal.

If you sell crypto once to load a fiat balance, record that sale and then the card purchases in fiat. If the provider converts crypto at each payment, keep every conversion with its matching purchase. If spending draws on a credit line against crypto collateral, keep the borrowing, collateral, interest, repayment and any liquidation records. Nexo Card, for example, is a dual-mode card, and its credit mode means borrowing against your crypto (as of 26 Sep 2026).

Stablecoins can move in value too, and a dollar-linked token changes value in euros or another reporting currency even while it stays near one dollar. Record swaps into and out of stablecoins like any other exchange: HMRC lists exchanging one cryptoasset for another as a disposal, and the IRS lists disposing of a digital asset for another digital asset. Link refunds and reversals to the original funding and purchase.

Example: wallet A starts with 1,000 units, receives 200 for work, sends 300 to your own wallet B and pays a 2-unit network fee, so A ends with 898. Wallet B receives 300 and later sells 100, so B ends with 200. Across both wallets, 1,098 = 1,000 + 200 − 100 − 2. The internal transfer of 300 cancels out in the combined ledger; it is not another 300 units of income.

If your import shows 1,398 units in total, B’s incoming 300 was probably counted without A’s outgoing entry. Match network, hash, amount, fee and ownership, and keep a correction log next to untouched exports. Balance the quantities first, then value each row.

Export the raw history from every platform before you lose access, for example before closing an account or moving country. Keep the untouched originals, your working ledger and secure backups. Reconcile opening units + receipts − disposals − outgoing transfers and fees against closing units, matching incoming transfers from your own wallets instead of counting them twice.

Give tax software read-only access where possible, and never share seed phrases or keys that can withdraw funds. Historical values come from documented price sources for the transaction date, not from today’s price.

Compare any provider tax statement with your own records. In the US, brokers report gross proceeds on Form 1099-DA for transactions on or after 1 Jan 2025 and basis for certain transactions on or after 1 Jan 2026. HMRC points out that exchange reports are not tax calculations and do not track pooled costs, so you keep your own records. If an identity or transaction detail in a provider report is wrong, ask for a correction through the provider’s verified support channel and keep the reply.

For each country and tax year, list your residence assumptions, your activity and every crypto event: receipts, sales, swaps, spending, rewards and transfers between your own wallets. Ask the adviser to identify the relevant countries, the residence period, how each event is classified and which cost-matching method applies, and only then to estimate the tax.

Keep the advice and the underlying documents together. A holding-period rule for private assets, where a country has one, concerns private investment gains; wages, business income and rewards follow their own rules.