Cryptocurrency taxation in Ukraine and Europe

Cryptocurrency has long ceased to be exclusively a tool for technology enthusiasts. Bitcoin, Ethereum, stablecoins, P2P transactions and cryptocurrency exchanges have become part of the financial lives of many Ukrainians.

Today, hundreds of thousands of Ukrainian citizens live in Poland, Germany, the Czech Republic, Portugal, Spain, France and other European countries.

This raises a very practical question: where should taxes on cryptocurrency be paid if it was purchased in Ukraine, held on a foreign exchange, and sold after moving to Europe?

This question is becoming increasingly relevant. The reason is the launch of DAC8, the European system for the automatic exchange of tax information on crypto-assets.

At the same time, it is important to immediately dispel two common myths.

DAC8 does not introduce a new tax on cryptocurrency, and spending 183 days in a country does not always automatically mean becoming a tax resident there.

In reality, when it comes to cryptocurrency taxation, at least four things need to be taken into account: tax residence → nature of the transactions → legislation of the particular country → documentation and tax reporting.

Now let us turn to the details.

Is cryptocurrency legal in Ukraine?

Ukrainian legislation has still not established a comprehensive special regulatory framework for crypto-assets.

The Law of Ukraine “On Virtual Assets” was adopted back in 2022, but as of September 2026, it has still not entered into force.

At the same time, work on new legislation is ongoing.

Draft Law No. 10225-d, aimed at regulating the circulation of virtual assets and related tax matters, was adopted at first reading in September 2025. As of September 2026, it is being prepared for its second reading. Therefore, its provisions should not be treated as current legislation.

This is an important point.

The absence of a special law on cryptocurrency does not mean that cryptocurrency is illegal or that income from it is automatically exempt from taxation.

Ukrainian tax authorities apply the general provisions of the Tax Code to such income.

How is cryptocurrency taxed in Ukraine?

The Ukrainian approach remains one of the most controversial issues.

The State Tax Service of Ukraine (hereinafter — the STS), in its explanations, takes the position that an individual’s income from the sale of cryptocurrency is included in taxable income.

If the source of the payment is foreign, the STS treats such income as foreign-source income; if the payment is made by a resident individual in Ukraine, it is treated as other income.

At the same time, the STS expressly states that, under this approach, the amount of funds received from cryptocurrency transactions is subject to taxation. However, the STS itself emphasizes that each situation must be assessed taking into account the specific documents and circumstances.

This is crucial.

For example, a person purchased Bitcoin for $20,000 and sold it several years later for $50,000. The economic profit is $30,000.

However, the Ukrainian tax approach to determining the taxable base for crypto transactions cannot simply be equated with the classic “sale price minus purchase price” model.

Therefore, determining the taxable base in Ukraine is one of the key issues that should be assessed on an individual basis.

What if you do not sell the cryptocurrency?

Here too, it is necessary to distinguish between different types of transactions.

Purchasing cryptocurrency with fiat currency and subsequently holding the asset is not the same as:

selling cryptocurrency
P2P transactions
using cryptocurrency to pay for goods or services
receiving cryptocurrency as payment for work
mining
staking
systematic trading that may have characteristics of professional or business activity.

Therefore, the question “I just trade crypto” is not sufficient for tax analysis.

It is necessary to establish exactly what transactions were carried out and what legal and economic result they produced.

Tax residence after moving to Europe

Let us imagine the following situation.

A Ukrainian citizen purchased Bitcoin in Ukraine in 2021. In 2024, they moved to Poland. In 2026, they sold part of their Bitcoin through a cryptocurrency exchange.

Where does the tax liability arise in this case?

The answer is not determined solely by the country where the cryptocurrency was purchased, the country where it was sold, or the place where the cryptocurrency exchange is registered.

For a proper assessment, it is necessary to establish:

where the person was a tax resident in the relevant year
when and at what value the asset was acquired
what transactions were carried out with it
when the taxable event occurred
how the transaction is classified under the law of the country of residence
what expenses can be documented
whether a double taxation treaty applies
what information about the transactions may be obtained by the tax authorities.

For Ukrainians living abroad, determining tax residence is often more important than the tax rate itself.

Citizenship alone does not determine tax residence.

Likewise, simply obtaining temporary protection in Poland, Germany or another country does not provide a universal answer regarding tax status.

Each country has its own criteria.

For example, Poland considers an individual a tax resident if they have their center of personal or economic interests in Poland or stay in the country for more than 183 days in the relevant tax year. If two countries simultaneously consider a person to be their tax resident, the rules of the applicable double taxation treaty are used.

In Germany, the criteria are formulated differently: unlimited tax liability generally arises, among other cases, for an individual who has a Wohnsitz – a place of residence – or a gewöhnlichen Aufenthalt – habitual abode – in Germany.

In Portugal, staying in the country for more than 183 days is one of the criteria, but a person may also become a tax resident after spending less time there if they have a home under circumstances indicating an intention to use it as their habitual residence.

Therefore, the rule “183 days = tax resident” is an oversimplification. In each individual case, factors such as housing, family, employment, business activities, economic ties, actual place of residence and the provisions of international treaties may be relevant.

That is why, after moving to another country, it is not enough simply to determine where the cryptocurrency was purchased or sold. The first step is to establish which country considers the individual to be its tax resident and what rules it applies to the relevant crypto-asset transaction.

Cryptocurrency taxation in Europe

The European Union has not established a uniform personal income tax rate for cryptocurrency transactions. Taxation rules are determined primarily by national legislation, which is why there are significant differences between European countries.

In some countries, the length of time an individual has held a crypto-asset is a key factor; in others, every gain from the disposal of a crypto-asset may be taxable. The tax treatment of exchanging one cryptocurrency for another, the deduction of acquisition costs, and the taxation of professional activities, mining, or staking also vary between countries.

Therefore, it is impossible to determine tax obligations based solely on the tax rate. The first things to consider are tax residence, the nature of the transaction, and the rules of the particular country.

Below, we will examine how these rules work in Poland, Germany, the Czech Republic, Portugal, Spain, France, and Italy.

Poland

The Polish system is one of the most formalized.

The tax rate on income from the taxable disposal of cryptocurrency is 19%.

At the same time, the costs of acquiring cryptocurrency may be taken into account when determining income, while excess unused costs can be carried forward to the following tax year.

Importantly, the Polish tax authorities expressly state that exchanging one virtual currency for another is not taxable.

Thus, the Polish model differs significantly, for example, from the Spanish approach.

Germany

In Germany, crypto-assets held by a private investor may fall under the rules governing private disposals pursuant to § 23 of the German Income Tax Act (Einkommensteuergesetz).

For the relevant private transactions, the period between the acquisition and disposal of the asset is of fundamental importance.

There is also a specific annual threshold: if the total gain from relevant private disposals does not exceed EUR 1,000, it is exempt from taxation under the applicable rules.

The German Federal Ministry of Finance also provides specific guidance on the taxation of crypto-asset exchanges.

Therefore, the statement “I held Bitcoin for one year, so there is no tax” should not be treated as a universal rule. It must first be established whether the private-asset regime actually applies and what transactions were carried out.

Czech Republic

Since 2025, the Czech Republic has had special rules concerning exemptions for income from the disposal of crypto-assets.

They include, in particular:

value test — CZK 100,000 of disposal proceeds during the relevant tax period
time test — more than 3 years of holding, subject to the statutory conditions.

A special CZK 40 million limit also applies to the relevant exemption based on the time test.

The general personal income tax rates in the Czech Republic are 15% and 23%, with the higher rate applying to the portion of the tax base exceeding the statutory threshold.

Portugal

Portugal applies a specific approach to crypto-assets.

For relevant taxable gains, the basic tax rate is 28%, although under certain conditions the taxpayer may opt to include the income in the general tax base.

At the same time, the law provides an important exemption: gains and losses from transactions involving crypto-assets held for at least 365 days are excluded from taxation under the applicable rules.

In certain cases provided by law, exchanging one crypto-asset for another does not create an immediate tax liability, and the acquisition value of the new asset is determined based on the value of the asset transferred.

At the same time, professional activities, mining, and other forms of income generation may be subject to different rules.

Spain

In Spain, gains from cryptocurrency transactions are taxed as part of the savings tax base.

For 2025 and subsequent years, the official tax scale is:

19% – up to EUR 6,000
21% – from EUR 6,000 to EUR 50,000
23% – from EUR 50,000 to EUR 200,000
27% – from EUR 200,000 to EUR 300,000
30% — over EUR 300,000.

A distinctive feature of Spain is that exchanging one cryptocurrency for another may have tax consequences because it is treated as an exchange of assets.

Therefore, a transaction such as Bitcoin → Ethereum does not necessarily mean that no tax is due.

France

In France, for a private investor, gains from transactions involving personal crypto-assets are taxed under the PFU regime – the flat tax.

As of 2026, the rate is 31.4%, consisting of 12.8% income tax and 18.6% social contributions.

Different rules may apply to professional activities, mining, and staking.

The exchange of digital assets without additional payment is also subject to a special tax deferral regime.

Italy

In Italy, the rules changed significantly from 2026.

For gains and other income from crypto-assets realized from January 1, 2026, the general special tax rate is 33%. At the same time, the previous EUR 2,000 threshold was abolished.

However, there is an important exception.

A 26% rate applies to certain euro-denominated e-money tokens that meet the statutory criteria.

DAC8: What is changing for cryptocurrency holders?

DAC8 is not a new tax. It is a system of tax transparency and automatic exchange of information on crypto-assets between tax authorities.

The DAC8 rules apply from January 1, 2026, making 2026 the first DAC8 reporting year.

The first automatic exchange of information based on 2026 data must take place no later than September 30, 2027.

This is one of the most significant changes for cryptocurrency holders in recent years.

DAC8 provides for the collection and transmission of information by reporting crypto-asset service providers.

This includes, in particular:

user identification
tax residence
information about crypto-assets
aggregated amounts of relevant transactions
purchases and sales of crypto-assets for fiat currency
exchanges of one crypto-asset for another
certain transfers of crypto-assets.

The information is provided to the national tax administration, after which data concerning non-residents is exchanged with the tax administration of their country of tax residence.

Therefore, statements such as “The tax authorities can now see every crypto wallet I have” or “Cryptocurrency remains completely anonymous” are both incorrect oversimplifications.

DAC8 does not mean total monitoring of every transaction on the blockchain. However, it significantly reduces the ability to rely on the assumption that transactions conducted through centralized cryptocurrency exchanges remain invisible to tax authorities.

How is DAC8 being implemented into the legislation of European countries?

DAC8 is a European directive, but for practical application it must be implemented into national legislation.

Poland

Poland has already implemented DAC8.

The law on the exchange of tax information was signed in March 2026. The Polish Ministry of Finance expressly states that it introduces reporting and automatic exchange of information on crypto-asset transactions.

Importantly, transactions carried out from the beginning of 2026 are also subject to reporting, meaning transactions that took place before the new Polish provisions entered into force.

Germany

Germany chose to implement DAC8 through a separate dedicated law – the Crypto-Asset Tax Transparency Act.

It entered into force on December 24, 2025, and directly implements DAC8 into German law.

Portugal

Portugal already has national rules requiring reporting on crypto-assets.

In 2026, the relevant provisions were updated, including by Law No. 26/2026. Reporting service providers must provide tax authorities with information concerning users who are tax residents of Portugal.

Italy

Italy has also completed the national implementation of the relevant rules.

Decree No. 194 of December 10, 2025 contains a separate section on the automatic exchange of tax information concerning crypto-assets.

France

In France, the relevant rules are set out in the Tax Code and further detailed by Decree No. 2025-1276.

The decree entered into force on January 1, 2026, and applies to transactions carried out from that date, with the relevant information subject to reporting in 2027.

Czech Republic

The situation is different here.

As of September 2026, the Czech Republic has not yet completed the national implementation of DAC8.

Official parliamentary materials show that the relevant bill is still under parliamentary consideration. The Czech Ministry of Finance had previously expressly acknowledged the delay in transposing the directive.

This distinction is important: the date from which DAC8 applies at the EU level is not the same as the date on which a particular country completes its national legislative process.

Spain

Spain already has its own crypto-asset reporting mechanisms.

However, as of 2026, the tax administration’s official plan expressly refers to the future transposition of DAC8 and the need to establish the technical specifications for new reporting forms, including a new form for crypto-asset service providers.

Therefore, it would be incorrect to say that Spain “does not monitor cryptocurrency.” Spain already receives a significant amount of information under its own rules, but the full technical implementation of DAC8 is still in progress.

What does DAC8 mean for Ukrainians living in Europe?

Let us imagine a simple situation. You: bought Bitcoin in Ukraine → moved to Poland → became a Polish tax resident → use a cryptocurrency exchange → sold part of your Bitcoin in 2026.

In such a situation, several levels need to be considered at once.

First – tax residence

Are you a tax resident of Poland?

Second – Polish tax legislation

What exactly was the transaction, and how is it taxed in Poland?

Third – documentation

Can you confirm when and at what price you purchased the Bitcoin?

Fourth – DAC8

Is the exchange or other service a reporting crypto-asset service provider that is required to collect and transmit the relevant information?

It is the combination of these four factors that provides the answer to the question of the tax consequences.

The documents confirming the history of cryptocurrency transactions are particularly important.

The longer this history, the more important it is to be able to document the origin and movement of the assets. If cryptocurrency was purchased several years ago, subsequently transferred between different wallets, exchanged for other assets, partially sold through P2P, while another portion remained on an exchange, a statement covering only the most recent transaction may not be sufficient.

It is advisable to keep:

cryptocurrency exchange transaction history
proof of cryptocurrency purchases
bank payment records
P2P transaction data
information on fees paid
blockchain transaction hashes
records of transfers between your own wallets
documents explaining the source of funds.

This is important not only for filing a tax return. If a bank, cryptocurrency exchange, or tax authority conducts a review, another question may arise: can you provide documentary evidence explaining the origin of your cryptocurrency and funds?

This is precisely where DAC8 matters. It does not create a new tax on cryptocurrency. Its practical significance lies in increased tax transparency and the exchange of information on crypto-asset transactions between the tax authorities of EU countries.

Therefore, for a Ukrainian who has moved to Europe and continues to use cryptocurrency, the question is no longer simply “how much tax do I have to pay?” It is important to understand where you are a tax resident, what transactions you carried out, how they are taxed, and whether you can document the history of the origin and movement of your assets.

When should you review your tax risks?

Cryptocurrency taxation should be assessed on an individual basis if you have more than simply purchased an asset and held it, but instead have a complex transaction history or have changed your country of residence.

This is particularly relevant if you:

purchased cryptocurrency in Ukraine and later became a tax resident of another country
changed your country of residence over several years
used different cryptocurrency exchanges, P2P platforms, or multiple crypto wallets
exchanged one cryptocurrency for another, sold assets, or used them for payments
received cryptocurrency from employment, business activities, mining, staking, or other activities
do not have documents confirming the purchase of cryptocurrency and the source of funds
received an inquiry from a tax authority, bank, or cryptocurrency platform regarding your transactions.

In such situations, it is not enough to know the general tax rate. First, you need to establish your tax residence, determine the nature of the transactions, reconstruct their history, and check the rules of the country that has the right to tax them.

The earlier you do this, the more opportunities you have to properly document your transactions and avoid problems in the future.

Conclusion

At this point, cryptocurrency can no longer be regarded as an area that exists “outside the tax system.”

At the same time, there is no single European cryptocurrency tax.

In Poland, a 19% tax rate applies, while crypto-to-crypto exchanges are not taxable.

In Germany, the private-asset regime and the holding period are of fundamental importance.

In the Czech Republic, new tests based on CZK 100,000 and a three-year holding period apply.

In Portugal, the 365-day holding period is an important factor.

In Spain, exchanging cryptocurrencies may trigger tax consequences.

In France, private investors are subject to a 31.4% PFU.

In Italy, the general tax rate for crypto-assets is 33% from 2026, with a separate exception for certain euro-denominated e-money tokens.

DAC8 adds another fundamental element to this system – the automatic exchange of tax information.

Therefore, for a Ukrainian who owns cryptocurrency, the right question today is not: “What is the tax rate on Bitcoin?”

It is much broader: “Where am I a tax resident, what transactions have I carried out, what income did they generate, what costs can I substantiate, and what information about my transactions can the tax authorities obtain?”

The final tax outcome depends on the answers to these questions.

If you purchased cryptocurrency in Ukraine but currently live in Poland, Germany, the Czech Republic, Portugal, Spain, or another European country, your situation requires an individual assessment.

This is particularly important when significant amounts, a long transaction history, P2P transactions, multiple cryptocurrency exchanges, relocation between countries, or the need to explain the origin of crypto-assets are involved.

In such cases, it is better to assess your tax risks before filing a tax return or receiving an inquiry from a tax authority, rather than afterwards.

If you need to determine your tax residence, understand how your cryptocurrency is taxed, or assess the potential implications of DAC8 in your specific situation, seek individual legal advice.