Holding crypto and digital assets across borders: ownership, residency and the new reporting rules

Crypto moves across borders in seconds, and its owners often do too. Tax rules have caught up, and from 2026 a new international reporting system sends exchange and broker data to tax authorities automatically. For anyone with significant holdings, the questions are who owns the assets, where the owner lives when they dispose of them, and whether the records will support the figures.

How crypto is usually taxed

Most countries treat crypto as property. Individuals generally pay capital gains tax, or income tax on gains, when they dispose of it, and a disposal usually includes selling for money, swapping one token for another and spending it. Income from mining, staking, lending and airdrops is often taxed as income when received, and that value becomes the cost for a later gain. The detail varies widely. Germany exempts private disposals of crypto held for more than a year; Portugal exempts gains of individuals on crypto held for 365 days or more, subject to conditions; the UK taxes each swap as a disposal and uses pooling rules to work out the cost.

Personally or through a company

Holding crypto through a company means gains are taxed at the corporate rate and costs and losses are handled inside the company, but profits paid out to the owner are taxed again. Moving existing holdings into a company is usually a disposal at market value, which can crystallise the very gain the owner hoped to shelter. A company is generally resident where it is managed, so a foreign company controlled by an owner at home may be taxed at home, and controlled foreign company rules can attribute its income to the owner. A company makes most sense for genuine business activity, such as a trading or staking operation with its own staff and systems.

Moving before a disposal

Gains are usually taxed by the country where the owner is resident when the disposal happens, so a move before a large sale can change the result. The rules are built to catch late or short moves. The UK taxes gains on assets held before departure if the person returns after a period of non-residence of five years or less. Some countries charge exit taxes when residents leave, and it is worth checking whether yours reaches digital assets or only shares. The country you move to may tax the whole gain on a later sale, including growth before you arrived, unless it gives a step-up in cost on arrival.

Reporting: CARF and DAC8

The OECD Crypto-Asset Reporting Framework (CARF) requires crypto service providers, such as exchanges and brokers, to collect identity and tax residence details from their users and report their transactions to the tax authority, which passes the information to the user's country of residence. In the EU, DAC8 applies the same approach from 1 January 2026, with the first exchanges between member states due in 2027. The UK began applying CARF from 1 January 2026, including reporting on UK-resident users. Many other jurisdictions have committed to start in 2026 or 2027, although timetables differ and some start later. The practical effect is that tax authorities will be able to match transaction data against tax returns. Anyone with undeclared gains from earlier years should consider a voluntary disclosure.

Record-keeping

• For every acquisition and disposal: the date, the asset, the quantity, the value in your home currency and the fees.
• A list of every wallet and exchange account you use, with evidence of which are yours.
• Transfers between your own wallets, so they are not mistaken for disposals.
• Staking, lending and airdrop income, with values at the time of receipt.

Before you sign

• Before signing a lease abroad or instructing a large sale, check where you will be resident on the date of disposal and for the following five years.
• Before signing company documents to move holdings into a company, confirm whether the transfer is a taxable disposal.
• Check whether your current country charges an exit tax that reaches digital assets.
• Reconcile your records and past returns now, before CARF and DAC8 data reaches the tax authority.

Holding significant digital assets, or planning to move before a sale? Call us before you sell, swap or sign a lease abroad. The first 30-minute consultation is free, your dedicated consultant is available 24/7, and every request is answered within 24 hours.

General information, not advice. Tax rules change and depend on your facts. Greyridge Global coordinates and delivers cross-border tax and corporate work through appropriately licensed professionals in each jurisdiction. Legal, tax, immigration, fiduciary, and regulated services are provided by qualified advisors engaged for your matter. Nothing on this page is tax or legal advice.