The Italian Tax Regime for Holders of Crypto-Assets: Recent Legislative Developments

The Italian tax framework applicable to holders of crypto-assets has undergone a series of legislative changes in recent years. Most recently, Law No. 207/2024 (the 2025 Budget Law) introduced further significant modifications. In particular:

-          As of 1 January 2025, the €2,000 exemption threshold provided under Article 67, paragraph 1, letter c-sexies of the Italian Income Tax Code (TUIR) for capital gains derived from crypto-assets has been abolished. In practice, this means that all capital gains, regardless of their amount, must be declared and will be subject to taxation.

-          As of 1 January 2026, the tax rate on capital gains from crypto-assets will increase from 26% to 33%.

However, the legislator has introduced a transitional provision allowing crypto-asset holders to opt for the revaluation of their holdings by electing to adopt the fair market value as at 1 January 2025 as their tax basis, in lieu of the original purchase price. This option is intended to mitigate the increased tax burden on future capital gains.

To exercise this option, taxpayers must pay a substitute tax of 18% on the revalued amount by 30 November 2025, or alternatively, elect to pay in three equal annual instalments, subject to an annual interest rate of 3% on the second and third instalments. The substitute tax paid must be reported in Form RT of the Personal Income Tax Return (Modello Redditi PF).

It should be noted, however, that exercising this option entails an obligation to prepay tax on unrealized (latent) capital gains, potentially requiring the liquidation of strategically significant or illiquid assets to meet the resulting tax liability. In this scenario, careful planning would allow for the combination of the preferential rule under discussion with other instruments available under the Italian legal system, in order to optimize the fiscal outcome.

In contrast, Switzerland offers a more favorable tax regime for private individuals holding cryptocurrencies. In particular, the disposal of crypto-assets by private investors is fully exempt from taxation.

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