Declaring Bitcoin in Italy: cripto-attività, 26 % flat and Quadro RT/RW

Italian bitcoin taxation was overhauled by Law 197/2022 (2023 Budget Law). Before that, taxation was unclear (treated by analogy with foreign currency rules). Since 1 January 2023, a clear framework applies : bitcoins are classified as "cripto-attività×Cripto-attivitàItalian legal term (law 197/2022) for crypto assets, taxed at a 26 percent flat rate above an annual threshold of 2,000 EUR.See in the lexicon →", and disposal capital gains are taxed at 26 % via a substitute tax (imposta sostitutiva).

Two mechanisms coexist. The 2 000 EUR annual exemption threshold : below that net annual gain, no taxation. Above, the 26 % applies to the entire gain (not only the excess). The Quadro RT×Quadro RT, Quadro RWSections of the Italian tax return covering crypto capital gains (RT) and holdings of foreign accounts (RW).See in the lexicon → of the income tax return declares the gain, the Quadro RW×Quadro RT, Quadro RWSections of the Italian tax return covering crypto capital gains (RT) and holdings of foreign accounts (RW).See in the lexicon → declares the foreign crypto holding (analogue of IVAFE for foreign financial accounts).

This article details the cripto-attività regime under L.197/2022, addresses the 2 000 EUR threshold and its computation, presents Quadro RT (substitute tax) and Quadro RW (fiscal monitoring), addresses the realignment (2023 fiscal revaluation at 14 %), covers the choice between regime amministrato and regime gestito, and lists the obligations specific to Italian and foreign exchanges.

Cripto-attività regime L.197/2022 and 26 % imposta sostitutiva

Before 2023, Italy did not have a dedicated tax framework for crypto-assets. The Agenzia delle Entrate likened them to foreign currencies, with an obscure regime based on circolare 72/E of 2016 (51,645 EUR holding threshold for 7 days to switch to taxable gain). The Legge di Bilancio 2023 (L. 197 of 29 December 2022) replaced this regime with the cripto-attività×Cripto-attivitàItalian legal term (law 197/2022) for crypto assets, taxed at a 26 percent flat rate above an annual threshold of 2,000 EUR.See in the lexicon →, autonomous category inscribed in article 67 paragraph 1 letter c-sexies of the Testo Unico delle Imposte sui Redditi (TUIR).

Legal definition. A cripto-attività is a digital representation of value or rights, transferable and storable electronically via distributed ledger×Ledger, Trezor, Coldcard, BitBoxMain hardware wallet brands. Ledger Nano S Plus / X (French, the best-seller), Trezor Model T (Czech, open source), Coldcard Mk4 (Canadian, ultra-secure, Bitcoin-only), BitBox02 (Swiss, open source).See in the lexicon → technology (DLT) or equivalent. Bitcoin, ether and stablecoins fall within the scope. NFTs also fall within, according to circolare 30/E of 2023, provided they are not qualified as artwork (distinct regime).

Taxable triggering events. Three operations trigger gain taxation:

• Sale against euro or another fiat×Fiat (fiat currency)State currency with legal tender status (euro, Swiss franc, dollar), issued by a central bank and not backed by a physical asset. By contrast, Bitcoin has an issuance capped at 21 million units, with no central issuer.See in the lexicon → currency (USD, CHF, GBP).
• Payment in cripto-attività of a good or service (buying a coffee at a Bitcoin merchant equates to a taxable disposal at day rate).
• Exchange×ExchangeService that lets you buy, sell and swap cryptocurrencies against fiat money. Examples : Kraken, Coinbase, Bitstamp, Bitvavo. Most are custodial.See in the lexicon → between cripto-attività of different categories. Crucial point: since 2023, exchanging BTC for ETH or for USDT is taxable. Only exchanging between cripto-attività « having the same characteristics and functions » is neutral, deliberately vague formulation of the law. The circolare 30/E specifies: BTC to BTC on another wallet×WalletSoftware or device that manages your Bitcoin keys and lets you sign transactions. A wallet does not really « hold » your bitcoins, it holds the keys that prove you own them.See in the lexicon →, exchange between stablecoins pegged to the same currency (USDT to USDC), or conversion between assimilated tokens of the same blockchain×BlockchainA public, shared ledger that records every Bitcoin transaction in blocks linked together cryptographically. Each participant in the network keeps a copy.See in the lexicon →.

Rate and threshold. Gain taxed at 26 % flat (imposta sostitutiva), without progressive scale. Annual allowance of 2,000 EUR: if the cumulated net gains of the year stay under this threshold, full exemption. This is a true allowance (Freibetrag), not a hard threshold (Freigrenze): at 2,500 EUR of cumulated gain, only 500 EUR are taxable (130 EUR of tax). It is more favourable than the German system where exceeding 1,001 EUR makes everything taxable.

33 % rise in 2027. The Legge di Bilancio 2025 inscribed a rate rise to 33 % from 1 January 2027, partially offset by a possible threshold lift to 2,500 EUR. The measure is subject to amendment at each annual finance law. Several Italian investors choose to materialise their gains in 2026 at 26 % rather than wait for the potential application of 33 %, but this decision depends on holding horizon and personal plans (property purchase, retirement, transmission).

Loss offset. Minusvalenze (realised losses) are deductible against year gains and against the 4 following years, provided they are declared on Quadro RT×Quadro RT, Quadro RWSections of the Italian tax return covering crypto capital gains (RT) and holdings of foreign accounts (RW).See in the lexicon →. A flat loss of 5,000 EUR in 2025 can absorb up to 5,000 EUR of cumulated future gain until 2029. Beyond, the loss is definitively lost. The offset operates only between cripto-attività, not with gains from other categories (shares, derivatives).

Gain calculation and LIFO method allowed

Taxable gain is calculated by difference between disposal price and acquisition price of the disposed cripto-attività×Cripto-attivitàItalian legal term (law 197/2022) for crypto assets, taxed at a 26 percent flat rate above an annual threshold of 2,000 EUR.See in the lexicon →. Italian law leaves to the taxpayer the choice of lot identification method: LIFO×LIFO (Last In First Out)Capital gains calculation method: the last units bought are deemed sold first. Italy uses it for crypto, unlike the French weighted average cost or FIFO.See in the lexicon → (Last In, First Out), FIFO×FIFO (First In First Out)Capital gains method that treats the first bitcoins bought as the first sold. Used in Germany, Italy and the United States.See in the lexicon → (First In, First Out) or weighted average cost (WAC). The choice must be consistent over the whole tax year but can change from one year to the next. This is a major difference with Germany (mandatory FIFO) and France (mandatory CGI prorata-temporis method).

Which method to choose. The LIFO method is generally most favourable in a sustained bull market×Bear market, bull marketProlonged falling market (bear) or rising market (bull). Bitcoin cycles have historically alternated between the two around halvings, with 70 to 85 percent drops in bear markets.See in the lexicon →: it attributes the sale to the most recent lots, whose purchase price is closest to the sale price, minimising the taxable gain. Conversely, in a bear market×Bear market, bull marketProlonged falling market (bear) or rising market (bull). Bitcoin cycles have historically alternated between the two around halvings, with 70 to 85 percent drops in bear markets.See in the lexicon →, LIFO maximises deductible losses (useful to carry forward over the 4 following years). FIFO becomes relevant when wanting to keep the most recent acquisitions (recent = potentially still at high expected return) and materialise older ones. The weighted average cost smooths timing effects and simplifies tracking for portfolios with many lots.

Worked example (Lucia case, LIFO method). Lucia accumulated 1.2 BTC over 24 monthly DCA×DCA (Dollar Cost Averaging)Buying a small fixed amount at regular intervals (for example 100 EUR a week), regardless of price. Smooths the average purchase cost and neutralises timing bias.See in the lexicon → purchases from January 2020 to December 2021 (then pause). Cumulated total cost: 31,000 EUR for 1.2 BTC, that is ~25,833 EUR/BTC weighted average. On 15 June 2026, she sells 0.1 BTC at 105,000 EUR/BTC for proceeds of 10,500 EUR. LIFO method: the lot sold is the last acquired, that is December 2021 purchase (0.05 BTC at 50,000 EUR/BTC for 2,500 EUR cost) + a fraction of November 2021 (0.05 BTC at 60,000 EUR/BTC for 3,000 EUR). LIFO cost attributed: 5,500 EUR. Gain: 10,500 - 5,500 = 5,000 EUR. After 2,000 EUR allowance: 3,000 EUR taxable. Imposta sostitutiva: 3,000 × 26 % = 780 EUR.

Same disposal, WAC method. Weighted cost 25,833 × 0.1 = 2,583 EUR. Gain: 10,500 - 2,583 = 7,917 EUR. After allowance: 5,917 EUR. Imposta: 1,538 EUR. Difference with LIFO: +758 EUR of tax. LIFO is clearly more favourable here because the latest DCA purchases (late 2021, cycle peak) are expensive and minimise the gain on partial sale.

No holding threshold. Unlike Germany, selling after 6 months or after 6 years does not change the Italian tax regime: 26 % flat on the gain above the 2,000 EUR threshold, whatever the holding duration. This uniformity simplifies exit calendar but removes the incentive for long patience that the German §23 EStGק23 EStG (Spekulationsfrist)German tax provision that fully exempts Bitcoin capital gains after a holding period of more than 12 months.See in the lexicon → creates.

Deductible fees. Trading platform commissions (Bitvavo, Coinbase, Kraken, Young Platform) and Bitcoin network fees (transaction fees×Transaction feesAmount paid to miners so they include your transaction in a block. Expressed in satoshis per virtual byte (sat/vB). Varies with network congestion.See in the lexicon →) are added to acquisition cost or subtracted from sale price, reducing the taxable gain. Document to keep. Subscription fees to a tax tool like Koinly are not deductible according to circolare 30/E.

Spreading strategy under the 2000 EUR threshold and 33 % rise in 2027

The annual 2,000 EUR allowance opens a central optimisation strategy for those who do not urgently need to liquidate everything. The principle is simple: each year, realise only the gain that keeps the net cumulated under the threshold. With LIFO×LIFO (Last In First Out)Capital gains calculation method: the last units bought are deemed sold first. Italy uses it for crypto, unlike the French weighted average cost or FIFO.See in the lexicon → on the Lucia case, selling about 0.04 BTC at 105,000 EUR per year generates ~1,800 EUR of gain, below the threshold and fully exempt.

Lucia simulation: full spread over 12 years. Lucia owns 1.2 BTC for 31,000 EUR cost (~25,833 EUR/BTC average). At a constant price of 105,000 EUR (simplifying hypothesis), each BTC sold generates ~79,167 EUR of average gain. By selling 0.04 BTC each year with LIFO on the most expensive lots, she absorbs the 2,000 EUR threshold and takes out 4,200 EUR net annually with no tax. Over 12 years, she liquidates 0.48 BTC for ~50,400 EUR of proceeds of which ~24,000 EUR of exempt gain. On the remaining 0.72 BTC, she pays 26 % imposta sostitutiva on the gain above the annual threshold.

The 26 % now vs 33 % in 2027 trade-off. With a rate rise to 33 % programmed for 1 January 2027 (subject to amendment by the next Legge di Bilancio), an investor planning to sell in the next 5 years may consider materialising a significant gain in 2026 rather than later. Concrete case: on 50,000 EUR of taxable gain above threshold, 26 % gives 13,000 EUR of tax, 33 % gives 16,500 EUR. Difference: 3,500 EUR. If the sale is deferred one year and BTC falls 20 % meanwhile, the gain shrinks and tax savings disappear. The decision is therefore not mechanically « sell in 2026 »: it depends on conviction on price and personal horizon.

Three pitfalls to avoid. First, the 2,000 EUR threshold is net of loss offset. A year loss reduces the counter; if the investor has 3,000 EUR of gain and 1,200 EUR of loss, the net is 1,800 EUR and stays below threshold. Second, taxable operations are not limited to euro sales: paying for a coffee in BTC or exchanging BTC for USDT also counts. An investor who occasionally pays in BTC can involuntarily tip above the threshold. Third, the 2 per mille bollo tax (0.2 % of the cripto-attività×Cripto-attivitàItalian legal term (law 197/2022) for crypto assets, taxed at a 26 percent flat rate above an annual threshold of 2,000 EUR.See in the lexicon → value held with an Italian provider at 31 December) applies even without sale, from 5,000 EUR of crypto patrimony. Lucia, with ~126,000 EUR of BTC in self-custody×Self-custodyModel in which you hold your own private keys. Your bitcoins depend on no third party. This is Bitcoin's founding promise.See in the lexicon → outside an Italian provider, owes no bollo, but must still declare on Quadro RW×Quadro RT, Quadro RWSections of the Italian tax return covering crypto capital gains (RT) and holdings of foreign accounts (RW).See in the lexicon →.

No allowance interruption by lending or DeFi. Unlike the German BMF doctrine which oscillated on the Spekulationsfrist in case of lending, Italy does not link the 2,000 EUR threshold to holding duration. Lending BTC on Ledn, Sphinx or Yield does not compromise the allowance. However, interest received (whether in BTC or USDT) constitutes capital income also taxable at 26 % flat (redditi di capitale category, no allowance, from the first euro). On 0.5 BTC lent at 4 % annual: ~2,100 EUR of interest generated in 2026, 26 % = 546 EUR of tax, to declare on Quadro RT×Quadro RT, Quadro RWSections of the Italian tax return covering crypto capital gains (RT) and holdings of foreign accounts (RW).See in the lexicon → section II with dedicated cripto-attività code.

5 practical cases: spreading, massive sale, lending, mining, bollo

The table below condenses the Italian tax treatment of five common situations for an Italian resident retail investor in 2026, 26 % rate in force (before 33 % rise planned for 2027). Amounts are indicative and exclude full personal situation.

Comments. The Lucia spreading case is the fiscal optimum for whoever can wait 12 years: she takes out 21,600 EUR cumulated without tax. The full 2026 sale captures a substantial gain but pays 24,180 EUR; compared to the 28,500 EUR of French PFU×PFU (Prélèvement Forfaitaire Unique)French 30 percent tax on capital gains, including crypto gains. Also called the « flat tax ». Made up of 12.8 percent income tax and 17.2 percent social levies.See in the lexicon → on the same base, Italy stays slightly more favourable, but remains far from Germany (0 EUR beyond 12 months) and Switzerland (0 EUR private gain).

Bitcoin lending falls into redditi di capitale and not into the cripto-attività×Cripto-attivitàItalian legal term (law 197/2022) for crypto assets, taxed at a 26 percent flat rate above an annual threshold of 2,000 EUR.See in the lexicon → regime: no 2,000 EUR allowance, taxation from the first euro at 26 %. Occasional mining falls into redditi diversi (open category ex art. 67) if irregular; if regular (Gewerbe equivalent), it tips into business income with progressive IRPEF up to 43 % + IRAP + INPS, a potentially very unfavourable situation.

2 per mille bollo tax. The last case illustrates an Italian particularity: the imposta di bollo (stamp tax) on cripto-attività held with an Italian provider (Young Platform, Bitcoin Suisse Italia, Binance Italia post-MiCA×MiCA (Markets in Crypto-Assets)European regulation 2023/1114 that frames crypto services across the EU since 2024. Creates the CASP status.See in the lexicon → 2025). Rate: 2 per mille (0.2 %) of value at 31 December, from 5,000 EUR of patrimony. It is the equivalent of IVAFE (imposta sul valore delle attività finanziarie estere) for foreign assets, extended to crypto. For Lucia in self-custody×Self-custodyModel in which you hold your own private keys. Your bitcoins depend on no third party. This is Bitcoin's founding promise.See in the lexicon → outside a provider, no bollo owed, but mandatory Quadro RW×Quadro RT, Quadro RWSections of the Italian tax return covering crypto capital gains (RT) and holdings of foreign accounts (RW).See in the lexicon → declaration.

Combined cases: Lucia only HODLs and partially sells in the table. An investor who stacks lending + short sale + mining adds up the taxations and progressively loses the beneficial effect of the allowance. The Italian regime rewards the discipline of a pure Bitcoin self-custody portfolio without annexed income generation.

Quadro RT, Quadro RW forms and Modello Redditi PF

The Italian tax declaration is made via the Modello Redditi Persone Fisiche (formerly Unico), to be transmitted electronically on the Fisconline (individuals) or Entratel (professionals and intermediaries) portal of the Agenzia delle Entrate. Free access with SPID (Sistema Pubblico di Identità Digitale), CIE (Carta d'Identità Elettronica) or CNS (Carta Nazionale dei Servizi).

Three quadri to know for Bitcoin.

Quadro RT×Quadro RT, Quadro RWSections of the Italian tax return covering crypto capital gains (RT) and holdings of foreign accounts (RW).See in the lexicon →, sezione II and II-A. « Gains of financial nature » on cripto-attività×Cripto-attivitàItalian legal term (law 197/2022) for crypto assets, taxed at a 26 percent flat rate above an annual threshold of 2,000 EUR.See in the lexicon →. Section II-A for gains from operations art. 67 c-sexies TUIR. One line per taxable disposal (or grouping by cripto-attività category if WAC method). Columns: cripto-attività code, acquisition date, disposal date, fiscal acquisition value, disposal price, gain (or loss if negative sign). At the bottom of section, 2,000 EUR threshold calculation and 26 % imposta sostitutiva. Carry-forward minusvalenze are declared on RT section IV.

Quadro RW×Quadro RT, Quadro RWSections of the Italian tax return covering crypto capital gains (RT) and holdings of foreign accounts (RW).See in the lexicon →. Declaration of cripto-attività patrimony held abroad or in self-custody×Self-custodyModel in which you hold your own private keys. Your bitcoins depend on no third party. This is Bitcoin's founding promise.See in the lexicon → outside an Italian provider. Mandatory for any Italian resident holding cripto-attività on 31 December, regardless of amount (no minimum threshold, unlike the old 15,000 EUR rule for classical foreign accounts). Main columns: code 14 (cripto-attività), value at 31/12 (calculated according to the December average rate published by the Agenzia delle Entrate or a reference site like CoinMarketCap), country of location (according to provider location or default Italy for self-custody of an Italian resident). For Lucia with BitBox02 in self-custody: country code Italy (self-custody assimilated to Italian holding by Agenzia 2024 doctrine), value 126,000 EUR at 31/12/2025.

Quadro RW sanctions. Non-compliance with RW declaration exposes to an administrative sanction of 3 % to 15 % of the undeclared amount (article 5 DL 167/1990). Doubled sanction (6 % to 30 %) if holding is in a « non-cooperative » country (blacklist, outside EU/EEA jurisdictions and outside OECD treaty States). Holding on a German or French self-custody wallet×WalletSoftware or device that manages your Bitcoin keys and lets you sign transactions. A wallet does not really « hold » your bitcoins, it holds the keys that prove you own them.See in the lexicon → does not trigger the reinforced sanction.

Imposta di bollo (Quadro RW column 8). If holding is with an Italian provider, the 2 per mille bollo tax is calculated automatically by the provider and withheld. If self-declared via Quadro RW, the taxpayer himself calculates 2 per mille of the 31/12 value and pays it via F24 with tax code 4047 before 30 June of the following year.

Declaration calendar 2026. The Modello Redditi PF 2026 (income 2025) must be filed via Fisconline before 30 November 2026 (usual deadline, sometimes extended). The F24 prepayment on imposta sostitutiva is due before 30 June 2026 (advance) then balance on 30 November 2026. Late penalties: 0.1 % per day late for the first 15 days, then 1.5 % per month (article 13 DLgs 471/1997).

Documents to keep. Article 43 DPR 600/1973 imposes document retention for 5 years from declaration. For Bitcoin: monthly CSV exports of each platform, blockchain×BlockchainA public, shared ledger that records every Bitcoin transaction in blocks linked together cryptographically. Each participant in the network keeps a copy.See in the lexicon → txids, Koinly/CoinTracking/CryptoBook (Italian alternative) tax reports with LIFO×LIFO (Last In First Out)Capital gains calculation method: the last units bought are deemed sold first. Italy uses it for crypto, unlike the French weighted average cost or FIFO.See in the lexicon →/FIFO×FIFO (First In First Out)Capital gains method that treats the first bitcoins bought as the first sold. Used in Germany, Italy and the United States.See in the lexicon →/WAC breakdown, source-of-funds justifications. An investor audited in 2031 on her 2026 declaration must be able to reconstitute all the acquisition history of her BTC since 2020.

Special cases: IT-CH/AT/FR cross-borders, DAC8, inheritance

Four situations fall outside the standard case and deserve specific mention.

IT-CH cross-borders (Ticino, Lombardy, Valais). An Italian resident working in Switzerland (classic case of Lombardy to Ticino, Piedmont to Vaud cross-borders) remains subject to the Italian cripto-attività×Cripto-attivitàItalian legal term (law 197/2022) for crypto assets, taxed at a 26 percent flat rate above an annual threshold of 2,000 EUR.See in the lexicon → regime on his BTC held in self-custody×Self-custodyModel in which you hold your own private keys. Your bitcoins depend on no third party. This is Bitcoin's founding promise.See in the lexicon →. The Italy-Switzerland bilateral convention of 1976 (revised 2020 on cross-borders, agreement in force since 2024) requires the cross-border to be taxed in his country of residence for capital income, therefore Italy for Bitcoin. Swiss salary is subject to shared withholding (80 % Switzerland, 20 % Italy). For a Ticino cross-border holding 0.5 BTC on Bitcoin Suisse SA in Zug: mandatory Quadro RW×Quadro RT, Quadro RWSections of the Italian tax return covering crypto capital gains (RT) and holdings of foreign accounts (RW).See in the lexicon → declaration (Switzerland = country code CH = OECD treaty country = normal 3-15 % sanction), 26 % imposta sostitutiva on any sale.

IT-AT cross-borders (South Tyrol, Friuli). Italy-Austria 1980 convention more recent on fiscal data circulation. Similar regime: Italian residence = Italian regime on cripto-attività. DLgs 25/2024 transposing DAC8×DAC8European directive that requires crypto platforms to share tax data on their users with European tax administrations. Applicable from 2026.See in the lexicon → facilitates automatic information exchange×ExchangeService that lets you buy, sell and swap cryptocurrencies against fiat money. Examples : Kraken, Coinbase, Bitstamp, Bitvavo. Most are custodial.See in the lexicon → between Bolzano and Innsbruck, making occult holding impossible. A South Tyrol Italian holding BTC on Bitpanda Vienna is automatically reported to the Agenzia delle Entrate.

Italians residing in France or Germany. An Italian woman becoming French tax resident (183-day test + foyer + centre of economic interests) fully tips into the French regime: PFU×PFU (Prélèvement Forfaitaire Unique)French 30 percent tax on capital gains, including crypto gains. Also called the « flat tax ». Made up of 12.8 percent income tax and 17.2 percent social levies.See in the lexicon → 30 % on subsequent sales, loss of the 2,000 EUR Italian threshold. If she sold her BTC the day before moving to France, gain taxed in Italy at 26 % above threshold. This is the central fiscal motive pushing some Italians to materialise before moving. For Germany, the tip may be even more interesting if BTC are kept > 12 months after moving (§23 EStGק23 EStG (Spekulationsfrist)German tax provision that fully exempts Bitcoin capital gains after a holding period of more than 12 months.See in the lexicon → exemption), but requires true German residence (physical Anmeldung).

DAC8 and automatic exchange from 2026. Decreto Legislativo 25/2024 of 1 March 2024 transposed EU directive 2023/2226 (DAC8). From 1 January 2026, all CASP×CASP (Crypto-Asset Service Provider)Crypto service provider authorised under MiCA. Must obtain a licence in its home country, valid throughout the EU.See in the lexicon → (Crypto-Asset Service Providers) under MiCA×MiCA (Markets in Crypto-Assets)European regulation 2023/1114 that frames crypto services across the EU since 2024. Creates the CASP status.See in the lexicon →, approved in any EU country, must annually transmit to the client's residence country tax authority: holder identity, balances at 31/12, total disposals of the year, total acquisitions, interest and rewards received. The Agenzia delle Entrate thus receives in March 2027 (on financial year 2026) a pre-filled table of cripto-attività operations of each Italian resident on Bitvavo (NL), Coinbase Europe (IE), Kraken (US without EU CASP so outside direct scope), Bitpanda (AT), etc. Self-custody outside CASP remains outside DAC8 scope, but entry and exit via CASP are traced, and a discrepancy between Quadro RT×Quadro RT, Quadro RWSections of the Italian tax return covering crypto capital gains (RT) and holdings of foreign accounts (RW).See in the lexicon → declared and DAC8 data received almost automatically triggers an audit.