What does the revaluation of crypto assets involve?

The law allows taxpayers to revalue the tax value of crypto assets owned as of Jan. 1, 2025, by applying a substitute tax of 18 percent on the total value. This represents an increase from the previous rate, set at 14 percent in the 2023 maneuver.

An appraisal by an accountant is not required. This is because the substitute tax is applied to the full normal value of the crypto assets as of January 1, 2025, without considering the original carrying value. However, by adopting this method, it is not possible to use any capital losses in offsetting, making it crucial to carefully assess the convenience of the transaction. This greatly simplifies the process and reduces costs for affected taxpayers.

The deal offers cryptocurrency holders the opportunity to realign the tax value to market value, reducing the impact of future capital gains, which from 2026 will be taxed at 33 percent. In addition, the elimination of the €2,000 deductible means that all capital gains will be taxed regardless of the amount, broadening the tax base and generating new reporting requirements.

The revaluation must be carried out by November 30, 2025, and the payment of the substitute tax can be divided into up to three equal annual installments, with the first to be paid by the same due date. For those who opt to pay in installments, interest of 3 percent is charged on the installments following the first. However, it is important to note that the measure applies only to individuals, as per the reference to Article 67 of the TUIR, which regulates miscellaneous income. For those who opt to pay in installments, 3 percent interest is applied on installments following the first.

New rates for capital gains

As of Jan. 1, 2026, a substitute tax of 33 percent will be levied on capital gains and other income referred to in Art. 67, para. 1(c-sexies) of the TUIR. For 2025, the levy remains set at 26 percent, and transactions made by December 31, 2025, regardless of the date of financial settlement, will be taxed.

How does revaluation work?

1. Determination of value: The taxpayer must calculate the value of the crypto assets as of January 1, 2025, using market quotations. The normal value, determined from market quotations, is the value to which the 18 percent substitute tax is applied. This method eliminates the need to consider the original book value, simplifying the calculation but excluding the possibility of offsetting any capital losses.
2. Payment of substitute tax: On the total value, the rate of 18 percent is applied, without considering the original carrying value of the crypto assets. This means that the substitute tax is calculated on the full normal value as of January 1, 2025. In contrast, for ordinary capital gains taxation, the tax applies only to the difference between the normal value and the book value. Payment of the substitute tax can be made in a lump sum or divided into installments.
3. Documentation: You will need to keep documentary evidence of the declared market value and tax payment for possible future tax audits.

The capital gain calculation method and the importance of book value

Capital gains on crypto-assets are calculated as the difference between the sale value and the book value (historical cost or revalued value). A properly documented book value is essential to correctly determine the tax base and minimize the tax liability.

With revaluation, the book value is updated to the market value as of January 1, 2025, simplifying the determination of future capital gains. This avoids tax disputes and ensures more accurate and transparent management of taxes due.

Elimination of the 2,000-euro deductible

The deductible of 2,000 euros, introduced by the Budget Law 2023, is eliminated as of 2025. Therefore, even minimal capital gains will be subject to taxation, and it will be enough to make a profit of 1 euro to trigger the declaration obligation. This means increased tax compliance for all taxpayers, including those who until now were not required to declare income from cryptocurrencies.

Who is eligible for the measure?

Reevaluation is accessible to:

• Individuals resident in Italy;
• Subjects who have not already opted for alternative tax regimes on crypto-assets.

According to guidance from the Internal Revenue Service, only crypto-assets for which tax monitoring requirements have been met can be revalued. The revaluation must relate to each crypto-asset held. For example, if a taxpayer holds 10 bitcoins and 20 ethers, he or she may decide to revalue only the bitcoins, but all 10 bitcoins held will have to be included in the revaluation. This approach allows greater flexibility in portfolio management, but it imposes strict care in documenting the market value as of January 1, 2025 for each individual cryptocurrency chosen for franking. For example, if a taxpayer holds 10 bitcoins and 20 ethers, he or she may choose to revalue only the bitcoins, but all bitcoins held will have to be included in the revaluation.

Benefits of revaluation

• Reduced tax impact: By adjusting the tax value of crypto assets to the market value, taxation on future capital gains is limited.
• Tax simplification: The substitute tax eliminates the need for complex calculations related to historical cost.
• Financial planning: Investors can more accurately predict the tax burden.

Final considerations 

The revaluation of cryptocurrency assets represents an attractive opportunity for those wishing to optimize their tax position in view of the expected increase in the capital gains tax rate. However, it is important to carefully consider whether the 18 percent substitute tax is affordable relative to the current value of cryptocurrencies held.

In addition, the IRS’s increased focus on crypto-asset transactions, amplified by the elimination of the exemption and new European directives on automatic data exchange, requires more accurate management of tax reporting and monitoring obligations.

For more information or for assistance with the revaluation process, please do not hesitate to contact our team of experts. Tardy is by your side to help you make the most of the opportunities presented by the tax changes.