Italy has a developed and structured crypto tax framework that is constantly updated.
The core legislative basis is Law 197/2022, which formally introduced capital gains taxation on crypto assets for Italian residents. Supplementary interpretive guidance was issued through Administrative Circular No. 30/2023 by the Agenzia delle Entrate (the Italian Revenue Agency), and Italy’s obligations under EU Regulation MiCAR (2023/1114) and EU Directive DAC 8 (2023/2226) have further shaped the reporting and enforcement landscape.
The Agenzia delle Entrate defines a crypto-asset as a digital representation of a value or right that can be transferred and stored electronically using Distributed Ledger Technology.
Italy uses the LIFO (Last In, First Out) accounting method for determining which units are treated as disposed of in a given sale, as confirmed by Resolution No. 788/2021 of the Agenzia delle Entrate.
This is significant for taxpayers who have accumulated holdings over multiple periods at varying prices. All Virtual Asset Service Providers (VASPs) operating in Italy are required to register with O.A.M. (Organismo Agenti e Mediatori), and as of 2024 approximately 2 million Italian crypto clients were on record through this registry, giving the Agenzia delle Entrate substantial visibility into domestic exchange-level transaction data.
Capital Gains Tax Rules
The legislative basis for capital gains taxation on crypto in Italy is Law 197/2022, with the Agenzia delle Entrate providing interpretive guidance in Administrative Circular No. 30/2023.
A taxable event arises when crypto assets are disposed of in a way that generates proceeds: selling crypto for fiat currency (euro), exchanging one type of crypto for another type with different characteristics or functions, and using crypto as payment for goods or services are all disposals.
However, certain activities are specifically classified as fiscally irrelevant and do not give rise to a taxable event: buying crypto with euros, holding crypto without disposal, transferring crypto between wallets owned by the same taxpayer, and exchanging crypto assets of the same type and function (for example, swapping one stablecoin for another of the same kind) do not trigger tax. The original cost basis carries forward in such non-disposal scenarios.
How CGT Is Calculated
The taxable gain is calculated as total disposal proceeds minus the total cost basis of the units disposed of, determined using the LIFO method.
The cost basis of a unit includes the acquisition price and any fees paid at the point of acquisition. Fees paid at the point of disposal are expressly not deductible, as confirmed by the Agenzia delle Entrate’s guidance.
All gains and losses from crypto disposals are netted across the fiscal year. A net gain is subject to the flat substitutive rate, 33% from 2026. A net loss (a negative annual result) may be carried forward and used to reduce taxable crypto gains in each of the four fiscal years following the loss year.
Losses not absorbed within the four-year window are permanently lost and cannot be carried back. Transaction fees and negotiation costs incurred at the point of disposal are not deductible, a notable distinction from the treatment in some other jurisdictions.
Record Keeping
Taxpayers are required to maintain records sufficient to substantiate the cost basis of all crypto holdings and the proceeds of all disposals.
Given the LIFO accounting requirement, records should be maintained in a format that identifies the acquisition date and cost of each tranche of holdings, allowing the LIFO calculation to be applied accurately. Exchange transaction histories, wallet records, and receipts for any fees paid at acquisition should be retained for each transaction.
Income Tax Rules
Income arising from crypto-related activities is taxed as personal income (IRPEF) under the progressive Italian income tax scale, with rates ranging from 23% at the lowest bracket to 43% at the highest.
This treatment applies to mining rewards, staking income, and wages paid in cryptocurrency, each of which constitutes income at the point of receipt rather than a capital event. The taxable amount in each case is the fair market value of the crypto received, expressed in euro at the date of receipt.
Wages paid in crypto tokens by an employer are treated as employment income under the labour income provisions of Italian tax law, valued at fair market value on the date of receipt, and are subject to IRPEF, social contributions, and any applicable withholding by the employer. Security token income is taxed under the financial income rules applicable to dividends and interest from conventional securities, at rates consistent with those applying to equivalent fiat income.
Where crypto-related activity gives rise to business income, for example, a company whose primary activity is market-making, exchange operation, or investment management in crypto assets, the profits are subject to corporate income tax (IRES) and regional production tax (IRAP) at the standard applicable rates, rather than the substitutive capital gains framework. The Agenzia delle Entrate assesses the nature of the activity in each case.
Mining and Staking Treatment
Mining
Mining income in Italy is treated as personal income subject to IRPEF at progressive rates of 23%-43%, not as capital gain.
The taxable amount is the market value in euro of the cryptocurrency received on the date each reward is credited. A distinction between business mining and hobby mining may be relevant: where mining is conducted as an organised commercial activity, it constitutes business income under Italian tax law, allowing the deduction of related expenses such as electricity, hardware depreciation, and relevant operating costs.
Where mining is conducted on a small or incidental basis, it may be assessed as miscellaneous income, potentially with more limited expense deductibility.
Upon the subsequent disposal of mined coins, a capital gains event arises. The cost basis for this CGT calculation is the fair market value in euro on the date the coins were received and taxed as income.
The applicable CGT rate applies to any appreciation in value between the date of receipt and the date of disposal. This two-stage tax treatment means that miners face both an income tax charge on receipt and a potential CGT charge on disposal.
Staking
Staking rewards are treated in Italy as income at the point of receipt, taxed under IRPEF at the taxpayer’s marginal rate.
The income is valued at the market price of the tokens received on the date of receipt.
As with mining, subsequent disposal of staked tokens gives rise to a capital gains event, with the cost basis set at the fair market value on the date of receipt. The Agenzia delle Entrate’s 2025 technical conference guidance confirmed that both mining and staking fall within the IRPEF income category rather than the substitutive capital gains regime at the point of receipt.
This means the effective tax rate on new tokens is materially higher than the flat CGT rate, though the CGT rate applies to any subsequent appreciation.
NFT Taxation
NFTs are classified as crypto-assets under Italian law, consistent with the EU Regulation MiCAR framework.
Their tax treatment follows the general principles applicable to other crypto assets. Where an NFT is held as an investment and subsequently disposed of, the transaction is assessed under the capital gains framework.
An exchange of an NFT for another type of asset with different characteristics and functions is a disposal, and the gain is calculated by reference to the fair market value of the NFT at the date of the exchange.
Where NFTs are created and sold commercially, the income received is more likely to be characterised as business income under IRPEF, or corporate income if conducted through a company, with the deductibility of related creation costs. The Agenzia delle Entrate has not issued specific published guidance addressing the distinction between investment NFTs and commercially created NFTs in detail beyond the general framework applicable to all crypto assets.
Reporting Requirements
Italian taxpayers must declare all crypto holdings and related income and gains through the annual tax return.
The primary vehicle for reporting is Modello Redditi (for self-employed individuals, those with capital gains, or those with foreign assets), due by 15 October. Capital gains from crypto disposals are reported on Form RT (capital gains from financial assets), which is filed as an attachment to Modello Redditi. Employment income received in crypto is reported through Modello 730 (the simplified employment income return), due by 30 September.
All crypto-asset holdings must be declared in the RW Section of Modello Redditi. A separate RW line must be completed for each wallet or custody account. Taxpayers who have entrusted crypto to an Italian intermediary that performs withholding tax on their behalf are exempt from the RW reporting obligation for those assets. Taxpayers who have lost their private keys must promptly file a loss report with the Agenzia delle Entrate to document the position.
The RW Section declaration serves both a tax reporting and a foreign assets monitoring function. The value to be reported is the market value of the holding at the end of the fiscal year. Failure to file the RW Section, or filing it with material errors, exposes the taxpayer to significant financial penalties. Under EU Directive DAC 8, Italian and other EU tax authorities exchange information on cross-border crypto transactions, substantially increasing the likelihood that unreported foreign holdings will be detected.
Penalties
The Italian penalty regime for crypto tax non-compliance operates on a graduated basis under the general administrative tax penalty framework.
Failure to file the RW Section, or filing it incorrectly, attracts significant monetary penalties, which the Agenzia delle Entrate has emphasised in its published guidance. For undeclared capital gains discovered in the course of an audit, the taxpayer faces the primary tax liability at the applicable rate plus a penalty calculated as a fraction of the tax owed.
Where the underpayment is self-reported before an audit is commenced, the penalty is reduced to one-sixth of the standard amount; where it is disclosed after an audit begins, the penalty rises to one-third or more.
Interest on late-paid tax accrues under the standard statutory provisions from the payment due date until actual settlement. The combination of the 33% capital gains rate from 2026, plus interest, plus penalties, can produce a materially higher effective cost of non-compliance than the tax itself. Italy’s VASP registration requirement with O.A.M. means that all domestic exchanges must report client holdings and transactions to the Agenzia delle Entrate, giving the Revenue Agency direct access to exchange-level data on approximately 2 million Italian crypto clients as of 2024.
A voluntary disclosure programme covering fiscal years 2016-2021 closed on 30 November 2023. That programme allowed taxpayers to regularise undeclared holdings and gains at significantly reduced rates: 0.5% on end-of-year values for RW reporting violations, and 3.5% on gross earnings for undeclared capital gains, representing a fraction of the standard liability. That programme is now closed, but the general voluntary disclosure provisions of Italian tax law remain available to taxpayers who wish to regularise historical non-compliance before an audit is initiated.
