Moving to cut your crypto tax: what actually changes, and what follows you.
Most of what is written about this compares headline rates. Headline rates are rarely the thing that decides it. Three other things are: whether the destination has a holding-period rule instead of a rate, whether a swap is a taxable event there at all, and whether the country you are leaving takes a bite on the way out. This page sets out all three for fourteen jurisdictions, cites every rule to its source, and computes nothing it cannot cite.
Three things that decide it, before any rate
The sale has to come after the move
A gain realised while you are still tax resident is taxed where you were resident, whatever your plans were. Residence turns on day counts, a permanent home and your centre of vital interests — and where two countries both claim you, a treaty tie-breaker decides, sometimes against you. The order of operations is the whole game, and it is the part people get wrong after the fact, when it cannot be fixed.
The exit tax usually wants shares, not coins
The United States, Canada and Australia deem you to have sold everything you own when you go, and crypto is property in all three. Germany, Spain, France, the Netherlands and Norway point their departure taxes at company shares, fund units and substantial interests — directly held coins fall outside. The trap is the exception: a crypto ETP or fund unit can sit inside a rule that a coin sits outside of.
A holding period beats a rate
Germany taxes a coin held thirteen months at nothing and one held eleven months at your full income rate. Portugal draws the same line at 365 days. Neither is a low-rate country; both can be a zero-tax outcome. Which means the date you acquired each lot decides more than the country does — and that date is the thing almost nobody can still prove.
Run your own numbers
We never guess a tax bracket, and we never guess an exchange rate. Enter your gain once; each country's rule is applied to that number in that country's own currency, without conversion. An FX assumption would move every row and it would be ours, not yours.
All fourteen, rule by rule
An individual holding crypto as private wealth. Business and professional activity is a different regime everywhere and none of this describes it.
United States
Under 366 days: your own rate · 366 days or more: your own long-term rate
Short-term at your ordinary rate, long-term at 0/15/20% plus the 3.8% net investment income tax where it applies.
Crypto for crypto: Taxable. A crypto-to-crypto swap is a disposal. Property, not currency.
Losses. Capital losses offset capital gains without limit, then $3,000 of ordinary income a year; the rest carries forward indefinitely.
Worth knowing. Your state is separate and this ignores it.
Sources: IRS Notice 2014-21 (crypto is property) · IRS Topic 409 — capital gains and losses. Retrieved 2026-08-28.
Germany
Under 366 days: your own rate · 366 days or more: exempt
Held more than one year: outside the charge entirely. Held less: your ordinary progressive rate, not a flat capital-gains rate.
EUR 1,000 a year. A Freigrenze, not an allowance: total private disposal gains under €1,000 in the year are free, and one euro over makes the whole gain taxable. Raised from €600 for 2024 onward.
Crypto for crypto: Taxable. The Bundesfinanzhof confirmed in 2023 that swapping one currency token for another is both a disposal and an acquisition.
Losses. Ring-fenced: private disposal losses offset private disposal gains only — never salary or investment income.
Worth knowing. Solidarity surcharge and church tax sit on top of the tax, not the gain. Whether staking or lending extends the period to ten years is contested in practice; the administrative position is that it does not, but read the 2025 BMF letter before relying on it.
Sources: § 23 EStG (private Veräußerungsgeschäfte) · BFH 14.02.2023, IX R 3/22 · BMF-Schreiben 06.03.2025 — Einzelfragen zu Kryptowerten. Retrieved 2026-08-28.
Portugal
citation pendingUnder 365 days: 28% · 365 days or more: exempt
Flat 28% under 365 days. At 365 days or more the gain is excluded from tax — and so, symmetrically, is the loss.
Crypto for crypto: Deferred. Crypto-for-crypto is not a taxable moment at all: the acquisition value of what you gave up carries into what you received, and tax waits for a disposal into fiat or goods. The single largest structural difference from Germany, Spain and the UK.
Losses. Category G losses carry forward five years — but a loss on a holding of 365 days or more is excluded along with the gain, so it cannot be used at all.
Worth knowing. Activity that is professional in character falls into Category B instead, where none of this applies.
Sources: AT — Criptoativos: conceito fiscal e tributação (Dec 2025) · Ofício Circulado n.º 20278 (17.03.2025) — Anexo G1. Retrieved 2026-08-28.
Italy
citation pending33% flat
A substitute tax of 33% from 1 January 2026 — up from 26%, and the €2,000 exemption that used to sit under it is gone.
Crypto for crypto: It depends. Swaps between crypto-assets with the same characteristics and functions are not realisation events; swapping across categories (an NFT for a payment token) is.
Losses. Excess losses carry forward against crypto gains for four tax periods. The compartment is closed — crypto losses do not reach equity gains.
Worth knowing. From 2026 euro-denominated e-money tokens meeting the MiCAR conditions keep a 26% rate, and conversion between euro and such a token is not a realisation.
Sources: Fondazione Nazionale Commercialisti — imposta sostitutiva sulle criptoattività · Agenzia delle Entrate — crypto-to-crypto is not a realisation event. Retrieved 2026-08-28.
Spain
19%–30% on a statutory scale
The savings scale: 19% to 30%, computed on the gain itself. No holding period — a one-day gain and a ten-year gain are taxed identically.
Crypto for crypto: Taxable. Treated as a barter (permuta): the gain is measured against the greater of the market value given or received.
Losses. Net savings losses offset investment income up to 25% of it; the remainder carries forward four years. Losses from a platform failing to return your coins are general income, not savings income — a different box with different timing.
Worth knowing. The scale we compute is the state and autonomic halves added together; your autonomous community sets its own half and can differ.
Sources: AEAT — compraventa de monedas virtuales por un inversor · AEAT — gravamen de la base liquidable del ahorro. Retrieved 2026-08-28.
United Kingdom
18% (basic rate band) / 24% (higher or additional rate)
Capital gains tax at 18% within the basic rate band and 24% above it, on gains after the annual exempt amount.
GBP 3,000 a year. A true annual exempt amount for 2026-27: only the excess is taxed.
Crypto for crypto: Taxable. Exchanging one token for a different type of token is a disposal. Moving coins between your own wallets is not — beneficial ownership never changes.
Losses. Allowable losses go against gains of the same year and must be claimed within four years of the end of the tax year of disposal; unused losses carry forward indefinitely.
Worth knowing. Section 104 pooling applies, so your basis is a running average per token — not the lot-by-lot chain a US return needs.
Sources: gov.uk — Capital Gains Tax rates and allowances · HMRC CRYPTO22100 — what counts as a disposal. Retrieved 2026-08-28.
Netherlands
No disposal tax — 6% deemed return taxed at 36% a year
There is no tax on the disposal at all. Box 3 charges a deemed return on what you held on 1 January — whether or not you ever sell.
EUR 59,357 a year. Tax-free capital for 2026: €59,357 per person, €118,714 for fiscal partners.
Crypto for crypto: Not taxable. Nothing you do during the year is a taxable event; only the 1 January balance counts.
Losses. Under the counter-evidence rule you may elect to be taxed on your actual return, which includes unrealised falls in value — but a negative year is set to zero and cannot be carried to another.
Worth knowing. Mining at a profit, or anything involving labour beyond investing, leaves box 3 for box 1 and ordinary rates. The figure we show is an annual holding cost, not a one-off disposal tax — it is not comparable to the others without saying how many years you intend to hold.
Sources: Belastingdienst — cryptovaluta in box 3 · Belastingdienst — berekening box 3-inkomen 2026. Retrieved 2026-08-28.
Switzerland
No charge on a private-wealth disposal
A private capital gain is tax-free federally. In exchange, your holdings are in the cantonal wealth tax every year at market value.
Crypto for crypto: Not taxable. Irrelevant to a private investor — no gain is taxed either way. It matters only as evidence in the professional-trader test.
Losses. Not deductible — the mirror of the gains being untaxed.
Worth knowing. The exemption is not unconditional. Circular 36 sets five cumulative safe-harbour criteria — among them a minimum six-month holding period and annual turnover no more than five times your holdings at the start of the year. Fail them and gains become self-employment income with social contributions. Wealth-tax rates are cantonal and communal; we do not quote one.
Sources: ESTV — Kryptowährungen: Besteuerung · ESTV Kreisschreiben Nr. 36 — gewerbsmässiger Wertschriftenhandel. Retrieved 2026-08-28.
United Arab Emirates
No charge on a private-wealth disposal
No personal income tax and no capital gains tax on an individual. Private investment income is carved out of corporate tax regardless of amount.
Crypto for crypto: Not taxable. There is no charging provision to engage.
Losses. Nothing to relieve.
Worth knowing. Corporate tax can reach a natural person carrying on a licensed or commercial business with turnover above AED 1,000,000 a year. Personal investment for your own account, not requiring a licence, is excluded whatever its size.
Sources: UAE Government — taxation · Cabinet Decision No. 49 of 2023 — natural persons and corporate tax. Retrieved 2026-08-28.
Singapore
No charge on a private-wealth disposal
No charging provision for capital gains. A disposal is taxable only where the activity is trading in nature.
Crypto for crypto: It depends. A swap is a disposal in principle, but taxable on the same capital-or-revenue test as a sale for fiat.
Losses. Only trading losses exist to relieve; a capital loss is not recognised because there is no capital gains tax.
Worth knowing. The line is the badges of trade — intention at purchase, frequency, holding period, financing, organisation. There is no bright line and no holding period that guarantees the capital side.
Sources: IRAS — Income Tax Treatment of Digital Tokens (2nd ed., 30 Jan 2026). Retrieved 2026-08-28.
Malta
citation pendingNo charge on a private-wealth disposal
Malta's capital gains tax is a closed list of chargeable assets, and payment coins are not on it. Trading in them is income.
Crypto for crypto: Not taxable. Not a chargeable event for coins — there is nothing to charge. Relevant only as evidence of a trade.
Losses. Coin losses are not capital losses; trading losses follow ordinary income rules.
Worth knowing. The answer depends on the token class — financial tokens that are securities are inside the capital gains charge. Malta also taxes on residence plus domicile, and a resident non-domiciled individual is generally on the remittance basis, which can change the answer entirely.
Sources: Commissioner for Revenue — Guidelines on the income tax treatment of DLT assets. Retrieved 2026-08-28.
Latvia
25.5% flat
A unified capital income rate of 25.5%, with a further 3% on total annual income above €200,000.
Crypto for crypto: Taxable. Disposal includes crypto-to-crypto exchange.
Losses. Undocumented acquisition cost is the real exposure — without documentation the full proceeds can be treated as gain.
Worth knowing. Declaration is quarterly once quarterly capital income exceeds €1,000, otherwise annual.
Sources: ClearBasis country page — Latvia, with VID citations. Retrieved 2026-08-28.
Estonia
22% flat
A flat 22% on the gain from transfer of property. The planned 2026 rise to 24% was cancelled.
Crypto for crypto: Taxable. Selling for fiat, swapping for another crypto-asset and paying for goods are all disposals.
Losses. Not deductible for a private individual — profitable disposals are taxed one by one and losing ones cannot offset them. This is the harshest loss rule of any jurisdiction here.
Worth knowing. An investment-account deferral regime was extended toward crypto-assets acquired through regulated providers; sources conflict on its current scope.
Sources: ClearBasis country page — Estonia, with MTA citations. Retrieved 2026-08-28.
Lithuania
15% flat
15% personal income tax, rising to 20% on non-employment income above 120 average monthly wages — with the first €2,500 of gains on non-registrable property exempt each year.
EUR 2,500 a year. €2,500 a year on gains from non-registrable property, crypto-assets included; only the excess is taxable.
Crypto for crypto: Taxable. A swap is treated as one asset sold and another bought.
Losses. Deduction of acquisition price requires documentation.
Worth knowing. A 2025 reform introduces progressive rates on aggregate income from 2026; the final crypto treatment should be confirmed with the VMI.
Sources: ClearBasis country page — Lithuania, with VMI citations. Retrieved 2026-08-28.
What the country you are leaving charges on the way out
This is the question that decides whether the plan works, and it is answered before the destination matters at all.
United States
reaches coinsIRC § 877A expatriation tax
A mark-to-market deemed sale of ALL property the day before expatriation, with no asset-class carve-out — crypto is property and is caught. It applies only to a covered expatriate: a citizen giving up citizenship, or a long-term resident (green card in 8 of the last 15 years) ending residency, who also meets one of three tests — average annual net income tax above $211,000 for 2026, net worth of $2 million or more, or failure to certify five years of compliance on Form 8854. The deemed gain is reduced by $910,000 for 2026.
IRS — Expatriation tax · Rev. Proc. 2025-32 §§ 4.37–4.38 (2026 figures)
Canada
reaches coinsITA s. 128.1(4)(b) — deemed disposition on emigration
On ceasing residence you are deemed to have disposed of each property at fair market value. The exclusions are Canadian real property, business property of a Canadian permanent establishment, registered plans, and property you already owned if you were resident 60 months or less in the preceding ten years. Crypto is on none of those lists. Form T1161 is required if the total value of property owned on departure exceeded CAD 25,000; a deferral election is available but security must be posted above CAD 16,500 of federal tax owing.
Australia
reaches coinsCGT event I1
Ceasing Australian tax residence triggers a deemed disposal at market value of assets that are not taxable Australian property, and the ATO states in terms that CGT event I1 happens in relation to Bitcoin. There is an election to disregard the gain — but the price is that the asset is then deemed to be taxable Australian property, so Australia keeps taxing rights on the eventual real disposal even after you have left. No monetary threshold.
Germany
shares, not coins§ 6 AStG
Reaches only shares in corporations within § 17 EStG — a holding of 1% or more at some point in the previous five years. Directly held coins are other economic goods under § 23 EStG and are outside it. There is no German deemed disposal on emigration for crypto held directly. The trap is elsewhere: from 1 January 2025 § 19 Abs. 3 InvStG applies an exit tax to investment fund units held privately, and a crypto ETP or ETN may be a fund unit where a coin is not.
Spain
shares, not coins citation pendingArt. 95 bis LIRPF
Covers shares or participations in any type of entity, where you were resident in at least 10 of the 15 preceding periods and the holding exceeds €4,000,000 (or 25% and €1,000,000). The Dirección General de Tributos has ruled that a taxpayer's cryptocurrencies are not within its scope — they confer no rights over an entity. A token that does confer economic or political rights over an entity could be analysed differently.
France
shares, not coins citation pendingArt. 167 bis CGI
Applies to corporate rights, securities and rights over them, where you were French resident for at least 6 of the 10 preceding years and hold at least €800,000 in value or 50% of a company's profits. Digital assets, taxed domestically under a separate regime, are not on that list. A payment deferral exists, requested at least 90 days before the move.
impots.gouv.fr — exit tax · BOFiP BOI-RPPM-PVBMI-50-10-10-20 — assets in scope
Netherlands
shares, not coinsconserverende aanslag
The protective assessment is triggered by Dutch pension rights, a deducted annuity, a housing capital policy, or a substantial interest in a company. Ordinary box 3 savings, investments and crypto are on none of those lists — there is no crystallisation of unrealised crypto gains on emigration. The box 3 base is simply apportioned by period of residence.
Norway
shares, not coins citation pendingskatteloven § 10-70 (utflyttingsskatt)
The enumerated list is shares, fund units, share savings accounts, endowment insurance, employment options, partnership interests and financial instruments whose underlying asset is itself subject to the exit tax. Spot cryptocurrency is not named. The catch-all does reach a crypto product structured as a fund unit or ETF. Since March 2024 there is a NOK 3,000,000 allowance on the net unrealised gain, with payment immediately, in twelve interest-free instalments, or deferred twelve years with interest.
What this does not model
Citizenship-based taxation
A US citizen is taxed on worldwide income wherever they live. Moving abroad does not end a US filing obligation; only expatriating does, and that has its own tax. If you hold a US passport, every row on this page describes a second layer of tax, not a replacement for the first.
Treaties, and being resident twice
Leaving one residence does not automatically start another, and a badly timed move can leave you resident in both countries or neither. Treaty tie-breakers exist for exactly this, and they turn on facts about your life, not your intentions.
Wealth taxes and annual charges
Switzerland exempts the gain and taxes the holding every year; the Netherlands does not tax the disposal at all and charges a deemed return on the 1 January balance. A single disposal figure cannot be compared with an annual charge without knowing how long you intend to hold. We show the Dutch figure as one year, and say so.
An unpaid US balance can take the passport
None of the rates above matter if you cannot travel. A legally enforceable federal tax debt over $66,000 for 2026 — including penalties and interest, so the tax itself can be well under that — is certified to the State Department, and a passport application or renewal is denied. An instalment agreement entered before certification is a statutory bar to it; entered after, it is a thirty-day unwind. What the certification notice does and how it is reversed →
Everything about your life
Family, schooling, healthcare, a business you own, where your clients are, whether you can actually get a visa. Tax is one input into a decision with a dozen, and it is not usually the largest.
Questions people actually ask
Does moving actually stop the tax on gains I already have?
Only for disposals that happen after you have genuinely ceased to be tax resident where you are now. A gain realised while you are still resident is taxed there whatever your plans. Residence is decided by day counts, permanent home and centre of vital interests — not by a flight booking — and a tax treaty tie-breaker can hand you back to the country you thought you had left.
Will an exit tax catch my coins?
Usually not, if you hold coins directly. The United States, Canada and Australia have deemed-disposal rules that reach all property, crypto included. Germany, Spain, France, the Netherlands and Norway aim theirs at shares, fund units and substantial interests, and directly held coins fall outside. The exception that catches people: a crypto ETP or fund unit can be inside a rule that a coin is outside.
Why does the calculator not convert currencies?
Because an exchange rate would move every result, and it would be our guess, not your rate. We apply each country's rule to the number you type in that country's own currency and say so. The comparison worth having is between rules, not between our FX assumptions.
Which of these is best?
We do not answer that, and anyone who does without knowing your citizenship, family, business and treaty position is selling something. The page shows the rules and cites them; the decision needs a professional in both countries, and usually before you move, not after.
Does the holding period restart when I move?
The destination's rule applies to your acquisition date, not your arrival date — Germany's one-year clock and Portugal's 365 days run from when you acquired the coin. Proving that date is exactly the problem this software exists to solve, and it becomes harder, not easier, once your records are spread across two countries and a closed exchange.
The date you bought each coin decides this. Can you still prove it?
Every rule above that could save you money — Germany's one year, Portugal's 365 days, the US long-term rate — runs from the acquisition date of each individual lot. Not the average. Not the year. The lot. Rebuild that chain from your own transaction history for free, and see what is provable before you plan anything around it.
Every rate, threshold and statutory reference above was retrieved on 28 August 2026 from the source cited beside it. Where a claim carries a citation pending badge we reached the conclusion through an official secondary source and could not open the primary text; we say which, on the card. Tax law changes and this page is a starting point for a conversation with a professional in both countries, not a substitute for one. ClearBasis is tax software, not a tax adviser, and nothing here is advice.