Most EU guides quote one rate per country. The coin, a European bitcoin ETN and a US ETF share are three different tax regimes, and the famous 0% rules cover only one of them.
TL;DR. There is no single "bitcoin tax rate" in an EU country. What you hold decides the regime: the coin, a European bitcoin ETN, or a share in a US spot bitcoin ETF. Germany's one-year exemption and Portugal's 365-day relief are written for the first of those, not for securities: PwC puts German gains on financial investments at a flat 25% plus the 5.5% solidarity surcharge, 26.375% in total with no holding-period relief, and Portugal's relief applies to "crypto assets that are not securities". France is 31.4% on securities as of 2025, not 30%. Italy moved crypto-asset gains to 33% from fiscal 2026 while financial assets stay at 26%. Check the product, then the country, in that order.
Mục lục · 12 mục
- The structural mistake in almost every EU guide
- The three products
- The matrix: six countries, three products, tax year 2026
- Country notes
- Claims worth unlearning
- Why EU retail ends up in ETNs at all
- What MiCA does and doesn't do
- Wealth taxes and reporting forms
- A checklist before you file
- This is not tax advice
- FAQ
- Sources and further reading
The structural mistake in almost every EU guide
Search for bitcoin tax in Germany and you'll be told 0% after twelve months. Search for Portugal and you'll be told 0% after 365 days. Both statements exist in law. Neither is a statement about exchange-traded products.
The German twelve-month rule lives in the part of the income tax code that deals with private sales of movable assets. PwC's Germany summary describes it as a rule for "other capital gains", separate from the paragraph that covers financial investments. Portugal is even more explicit: the relief is written for "crypto assets that are not securities". An ETN is a security. So is a share in a US trust.
That gap runs one way: assuming the coin regime applies to your ETN underpays the tax, and that's the mistake that gets a letter. So this guide is a matrix, not a league table, and where we couldn't confirm a number in a source we say so instead of filling the cell.
The three products
The coin. Bitcoin held on an exchange or in your own wallet. In most EU countries this sits in a crypto-specific or general "other assets" regime, which is where the famous holding-period reliefs live.
A European bitcoin ETP. Physically backed notes listed on Xetra, SIX, Euronext and the LSE, from issuers like ETC Group, 21Shares, CoinShares, WisdomTree and Invesco. Legally these are debt securities, which is exactly why they can be sold to EU retail when a single-asset fund cannot. We're not quoting tickers or fees, because issuers reuse ticker letters across venues and the same product carries different codes in Frankfurt and Zurich. Pull the ISIN from your broker and read the issuer's factsheet.
A US ETF share. IBIT, FBTC and the rest are US-listed trusts. To a European tax office they're foreign securities, and in some countries foreign fund units carry extra rules. See the US fund overview for what they are.
The matrix: six countries, three products, tax year 2026
Rates are for individuals in a plain taxable account, sourced to the PwC summaries and tax authorities linked at the end.
| Country | The coin itself | European bitcoin ETN | US-listed ETF share |
|---|---|---|---|
| Germany | Private-sale rule: progressive rates only if sold within one year, and only on profit above €1,000 a year since 2024 | Financial investment: 25% plus the 5.5% surcharge, 26.375% in total, no holding-period relief, €1,000 allowance | Same flat regime in principle, but fund-unit rules with partial exemptions may apply. Ask an adviser |
| France | Separate regime for actifs numériques. Not covered by our sources, check impots.gouv.fr | Securities: PFU flat tax of 31.4% (12.8% plus 18.6% social levies) as of 2025, plus high-income surtaxes | Same 31.4% securities regime |
| Italy | 33% from fiscal 2026, up from 26%. Euro stablecoins stay at 26% | Financial asset: 26% substitute tax | 26% on financial assets, but confirm foreign fund treatment locally |
| Spain | All three land in the savings base: 19% to €6,000, 21% to €50,000, 23% to €200,000, 27% to €300,000, 30% above (2026) | ||
| Netherlands | No tax on the gain. Box 3 deems a return on 1 January value: 6.00% for investments and other assets in 2026, taxed at 36%, after a €59,357 allowance | ||
| Portugal | Category G gain, with relief for crypto assets held 365 days or more | Security: flat 28%, with partial exclusions of 10% to 30% of the gain for holdings over two, five and eight years | Same 28% securities regime and the same long-hold exclusions |
Two cells say "ask" instead of a number, which is the honest state of our sources.
Country notes
Germany: the 0% headline does not survive contact with a security
PwC's Germany page separates two things cleanly. Capital gains from financial investments, its example being the sale of shares, take a flat 25% plus the 5.5% solidarity surcharge, 26.375% together, normally withheld at source, with an investor's allowance of €1,000 a year per taxpayer, doubled for couples filing jointly. Nothing there gets cheaper if you hold longer. The twelve-month rule appears in a different sentence: other capital gains are taxable at progressive rates only if the sale happens within one year for movable assets or ten years for real property, and since 2024 only if the profit clears €1,000 a year.
Which paragraph catches a specific bitcoin ETC is a question about that product's legal terms, and one to put to a German adviser in writing. What you can't do is assume the one-year exemption applies because the note tracks bitcoin. US trusts add a wrinkle: PwC flags partial exemptions on gains from mutual fund units depending on the type of fund.
And the solidarity surcharge is 5.5% of the tax, not 5.5 points on the rate. That's where 26.375% comes from, and it doesn't turn a 45% marginal rate into 50.5%.
France: 31.4%, and it changed recently
The number most guides still print is 30%. PwC's France summary now reads: as of 2025, capital gains from the sale of securities are subject to the flat tax (prélèvement forfaitaire unique) of 31.4%, being 12.8% income tax plus social levies of 18.6%. The social levy went up, and that's the whole difference. High earners may also face the CEHR surtax of up to 4% and the differential contribution on high incomes.
You can still elect progressive rates instead, and low-income holders sometimes come out ahead, but the election covers all of your PFU income at once.
For the coin itself France runs a separate regime for actifs numériques. Our sources don't cover it, so we quote neither a rate nor a de minimis. Read the current page on impots.gouv.fr.
Italy: 33% on the coin, 26% on the note
This is the cleanest example of why the matrix matters. The Budget Law for fiscal 2026 raised the rate on capital gains and income from crypto-assets from 26% to 33%. The 26% substitute tax on financial assets didn't move, and euro-denominated stablecoins were carved out and kept at 26%.
So from 2026 the coin and the note that tracks it are taxed seven points apart. Which side a product sits on is a question about the instrument, not about bitcoin. As for the €2,000 annual floor that older guides cite, it doesn't appear anywhere in PwC's current Italy summary, so we've dropped it rather than repeat it. Confirm it with an Italian adviser if your gains are small enough for it to matter.
Spain: the same bands for everything, and the top band is 30%
Spain is the simple one. Gains go into the savings taxable base, and the 2026 bands are 19% on the first €6,000, 21% to €50,000, 23% to €200,000, 27% to €300,000 and 30% above. That last band is where guides go stale: 28% was the previous top rate and is still widely quoted.
Netherlands: you're taxed on owning, not on selling
Box 3 doesn't care what your bitcoin did. It deems a return on the value of your assets on 1 January and taxes that. The Belastingdienst's figures for the 2026 provisional assessment are 1.28% for bank deposits, 6.00% for investments and other assets, and 2.70% for debts. Crypto is listed under investments and other assets alongside shares and bonds, so the coin, the ETN and the US ETF share land in the same bucket. Box 3 income is taxed at a flat 36% after a tax-free allowance of €59,357, doubled to €118,714 with a fiscal partner.
Do the arithmetic and a stable holding costs roughly 2.16% of its 1 January value in 2026, whatever bitcoin does during the year. A flat year still generates a bill.
The 6.04% figure you'll see quoted was the 2024 rate. It was 5.88% for 2025 and 6.00% for 2026, so any "effective rate of about 2.2%" built on it is out of date. There's also an escape hatch: following Supreme Court rulings the tax authority must use your actual return where it's lower than the deemed one, and from 2025 that declaration sits inside the income tax return. The tax-free allowance doesn't apply in that calculation.
Portugal: the 365-day relief says "not securities" in so many words
Portugal's crypto regime, in force since 2023, treats gains on the disposal of crypto assets that are not securities as Category G capital gains, with relief where they were held for 365 days or more. The qualifier is in the rule itself.
A bitcoin ETN is a security, so it takes the ordinary route of a flat 28%. There is a long-hold benefit there too, but it's a partial exclusion rather than an exemption: since 2024, gains on securities admitted to trading and on investment fund units are excluded from tax by 10% after two years, 20% after five and 30% from eight. Separately, if you held for less than 365 days and your taxable income reaches €86,634, the balance of gains and losses is aggregated with your other income instead of taking the flat rate.
Claims worth unlearning
| Common claim | What the source actually says (2026) |
|---|---|
| "Germany is 0% after a year on any bitcoin product" | The one-year rule covers private sales of movable assets. Gains on financial investments are 26.375% with no holding relief |
| "Portugal is 0% after 365 days" | The relief is written for crypto assets that are not securities. Securities are 28% |
| "France is a flat 30%" | 31.4% on securities as of 2025: 12.8% plus 18.6% social levies, plus surtaxes for high earners |
| "Italy is 26%" | 33% on crypto-asset gains from fiscal 2026. 26% stays for financial assets and euro stablecoins |
| "Spain tops out at 28%" | The savings base tops out at 30% above €300,000 |
| "The Dutch deemed return is 6.04%" | That was 2024. It's 5.88% for 2025 and 6.00% for 2026 |
| "IVAFE is about €34 a year per crypto wallet" | €34.20 is the fixed charge per bank account. Financial investments held abroad are taxed at 0.2% of their 31 December value |
| "MiCA regulates bitcoin ETPs" | MiCA does not apply to crypto-assets that qualify as financial instruments |
Why EU retail ends up in ETNs at all
Two rules do the work. The UCITS Directive sets what can be sold to EU retail investors and is built on spreading risk across many holdings, so a fund holding one asset can't qualify. The PRIIPs Regulation requires a Key Information Document in the local language, and US issuers don't produce one because they don't market to EU retail. Between them, a retail client at a mainstream European broker generally can't buy IBIT or FBTC. European issuers route around the first rule by issuing debt securities instead of fund units, and that's exactly why the tax answer changes: the wrapper that solves distribution is the wrapper that takes you out of the crypto tax regime.
What MiCA does and doesn't do
MiCA is often described as the rulebook for crypto ETPs. It isn't. ESMA's final report on qualifying crypto-assets as financial instruments spells out the boundary: the exemptions in Article 2(4) of MiCA mean the regulation "does not apply to crypto-assets that qualify as financial instruments", along with deposits, funds, securitisation positions, insurance and pension products.
A listed bitcoin ETN is a transferable security, so it sits with the prospectus and market-conduct rules for securities, not with MiCA. Calling an ETP "MiCA-compliant" as a quality mark is a category error, and it tells you nothing about tax. MiCA changes no rate anywhere. National tax law governs.
Wealth taxes and reporting forms
Rates are only half the bill. Three regimes here charge you for holding rather than selling, or make you declare what you hold abroad.
- Italy, IVAFE. Financial investments held outside Italy are taxed at 0.2% of their value at 31 December, rising to 0.4% in territories deemed to have privileged taxation. The flat €34.20 charge quoted elsewhere as a crypto wallet fee is the fixed IVAFE amount for a bank account, and it isn't due where the average annual balance is under €5,000. Italian-held financial investments carry a 0.2% stamp duty on the same base.
- Spain, Form 721. Order HFP/886/2023 introduced the obligation to report cryptocurrencies located overseas on form 721, in force since July 2023; for tax year 2025 the window ran from 1 January to 31 March 2026. That is the virtual currency form. The older duty to disclose overseas accounts, securities and real estate comes from a different law and a different form, so a European ETN at a foreign broker is not automatically a 721 item. Ask which form your holding belongs on.
A checklist before you file
- Identify the instrument first. Get the ISIN. A note, a fund unit and a coin balance are three answers in the same country.
- Pin the tax year. Italy changed in 2026, France in 2025, the Dutch percentages change annually. A rate without a year is a future error.
- Check where it's listed and where it's held. Foreign custody can trigger reporting forms and wealth taxes that have nothing to do with the gain.
- Don't plan around a holding-period exemption until you've confirmed it covers your wrapper. This is where the money is lost.
- Keep purchase dates and euro cost basis per lot. Every regime above needs at least one of them.
Comparing products before you buy rather than after? Our fund directory lists what each issuer runs, and the daily flow tracker shows where the money is going.
This is not tax advice
We write about ETF flows, not about your return. Everything here describes published rules for individuals, taken from the sources below and tied to the tax years named. Your answer depends on your residence, where your broker sits, whether you hold personally or through a company, and often on the product's terms. Rates change every budget season, sometimes retroactively, as France did. Check your own tax authority and talk to an adviser in your country before acting on any of it.
FAQ
Does the German one-year rule make bitcoin ETPs tax free?
Don't assume it. PwC's Germany summary puts capital gains from financial investments at a flat 25% plus the 5.5% solidarity surcharge, 26.375% in total, with no relief for how long you held and an allowance of EUR 1,000 a year. The one-year rule sits in a separate provision on other capital gains from movable assets. Which side a specific bitcoin ETC falls on turns on that product's terms, so get it confirmed in writing before planning around 0%.
Is Portugal still 0% on bitcoin after 365 days?
For crypto assets that are not securities, PwC states that relief applies where they were held for 365 days or more. That qualifier matters: an ETN is a security, so it takes the ordinary 28% flat rate. Securities get a partial long-hold benefit, an exclusion of 10% of the gain after two years, 20% after five and 30% after eight, but that is a discount, not an exemption.
What is the French flat tax on a bitcoin ETN in 2026?
PwC France states that as of 2025, capital gains from the sale of securities take the flat tax at 31.4%, made up of 12.8% income tax and 18.6% social levies, with the surtax for high earners of up to 4% and the differential contribution on high incomes on top where they apply. The older 30% figure reflects the previous social levy rate. You can still elect progressive rates, but the election covers all your flat-tax income at once.
Why is Italy 33% for crypto but 26% for a bitcoin ETN?
Because Italy taxes the asset class, not the exposure. PwC reports that the Budget Law for fiscal 2026 raised the rate on crypto-asset gains and income from 26% to 33%, while capital gains on financial assets stayed at the 26% substitute tax and euro stablecoins were kept at 26%. An exchange-traded note is a financial asset, so from 2026 the coin and the note that tracks it are taxed seven points apart.
How does the Netherlands tax a bitcoin ETF if there is no capital gains tax?
Box 3 taxes a deemed return on what you own on 1 January, regardless of what you sold. For the 2026 provisional assessment the Belastingdienst uses 1.28% for bank deposits, 6.00% for investments and other assets, and 2.70% for debts, taxed at a flat 36% after a tax-free allowance of EUR 59,357, doubled with a fiscal partner. Crypto sits under investments and other assets, so coins, ETNs and US ETF shares are treated alike. Following Supreme Court rulings you can declare your actual return where it is lower.
Does MiCA apply to bitcoin ETPs, and does it change my tax?
No on both counts. ESMA's final report on qualifying crypto-assets as financial instruments notes that the exemptions in Article 2(4) of MiCA mean the regulation does not apply to crypto-assets that qualify as financial instruments. A listed bitcoin ETN is a transferable security and falls under securities rules rather than MiCA. And no EU regulation sets income tax rates. That stays with national law.
Can EU retail investors buy IBIT or FBTC?
Generally not through a mainstream European broker. The UCITS Directive is built around spreading risk across holdings, so a single-asset fund cannot qualify for retail distribution, and the PRIIPs Regulation requires a Key Information Document that US issuers do not produce. Professional clients under MiFID II can often access US listings, but that adds reporting duties and changes nothing about your home rate.
Sources and further reading
- PwC Worldwide Tax Summaries, Germany: income determination (the 26.375% flat regime, the EUR 1,000 allowance, the one-year rule for movable assets) and France: other taxes (the 31.4% PFU on securities as of 2025).
- PwC Worldwide Tax Summaries, Italy: other taxes: 26% to 33% on crypto-assets for fiscal 2026, IVAFE at 0.2%, the EUR 34.20 bank account charge.
- PwC Worldwide Tax Summaries, Spain: personal income tax: the 2026 savings bands, 19% to 30%. Form 721 sits on the tax administration page.
- PwC Worldwide Tax Summaries, Portugal: other issues: the 365-day relief for crypto assets that are not securities. The 28% rate and long-hold exclusions are on the income determination page.
- Belastingdienst, box 3 percentages for 2026: 1.28% / 6.00% / 2.70%, plus the allowance table (EUR 59,357 for 2026).
- ESMA, final report on the qualification of crypto-assets as financial instruments (December 2024): the Article 2(4) MiCA exclusions.
- Internal: tax in the USA, tax in the UK, ETF vs spot bitcoin, what a bitcoin ETF is, tax-loss harvesting.
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