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Tax by country

Losses and matching rules

How capital losses are used, carried forward and restricted, and which sell-and-rebuy rules apply to crypto, in every country HQ Wealth supports.

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current
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HQ FS
Last verifiedStatus
28-10-2026approved by the owner (accountant), 28-10-2026

Related article: hq-fs.com/blog/crypto-tax-loss-harvesting-wash-sales

Not tax advice. General information for individuals, verified 28-10-2026. Confirm every rule with a qualified adviser before you file.

Scope: resident individuals who invest, not trade, unless a row says otherwise.

Losses by country#

CountryOffset againstRing-fenced?Carry forwardCarry backCrypto-specific rule
AustraliaCapital gains only. Applied before the 50% discountYes. Not against other incomeIndefinitelyNone stated in the ATO page Using capital losses to reduce capital gainsLosses on crypto that is a personal-use asset are disregarded. Lost private key: loss allowed if ownership is evidenced. From 01-07-2027 (proposed): set loss order; short-term crypto losses reduce deferred discounted gains
CanadaAllowable capital loss (half the loss) against taxable capital gains onlyYes. Not against other incomeIndefinitely3 yearsSame rules as other capital property. Crypto traded as a business gives business losses
FranceCrypto gains of the same year onlyYes. Not against other income or other gainsNoneNoneCrypto-to-crypto swaps are not taxable, so no loss arises on a swap. Gain or loss uses the household's global portfolio formula
Germany§23 (crypto) losses: §23 gains only. Capital-income losses: capital income only; share losses: share gains onlyYes, each categoryYes, via §10d1 year (§23 and §22 Nr. 3 losses). Capital-income losses: noneCrypto losses sit in §23. Lending income losses (§22 Nr. 3) only against §22 Nr. 3 income
IndonesiaNo relief. Crypto final tax is levied on gross transaction valuen/aBusiness losses on non-final income: 5 years—A crypto loss gives no tax relief
IrelandSame-year gains, then gains of later years. Applied before the EUR 1,270 exemptionYes. Not against incomeNo stated time limitNone, except losses in the year of death (3 previous years)No crypto-specific rule published. Losses on Irish and equivalent offshore funds get no relief
NetherlandsNo losses under the deemed-return regime. Counter-evidence route: negative actual return set to EUR 0n/aNone. From 2028 (adopted by the Tweede Kamer only): losses above EUR 500NoneCrypto is a Box 3 asset like any other
Nigeria2026: digital-asset losses only against digital-asset gains. 2025: sources disagreeYes (2026)2026: until fully recouped—Ring-fence is specific to digital assets
SingaporeCapital losses: not deductible. Trading (revenue) losses: other income of the same yearCapital losses: no relief at allTrading losses: until fully usedTrading losses: 1 year of assessment, capped at SGD 100,000Unrealised fair-value losses are not deductible
South AfricaAssessed capital loss: future capital gains only. Revenue crypto losses: income from the same crypto trade onlyYes, bothIndefinitely (assessed capital loss)None stated in the SARS page Assessed capital lossRevenue crypto losses ring-fenced under s20A(2)(b)(ix)
SwitzerlandPrivate investor: not deductible. Professional trader: deductible against income if bookedn/a (private)——Private crypto gains are tax-free, so private losses are not deductible
United KingdomSame-year gains first, then brought-forward losses down to the annual allowanceYes. No general offset against incomeIndefinitely. Loss must be claimed within 4 years of the end of the tax year of disposalNo general carry-back. Special rule on death existsLost private key: no disposal, but a negligible value claim may crystallise a loss
United StatesCapital gains, then up to USD 3,000 (USD 1,500 married filing separately) of other income per yearPartly. Ordinary-income offset cappedIndefinitelyNone stated in IRS Topic no. 409Crypto is property; ordinary capital loss rules apply

Sell-and-rebuy rules#

CountryRule nameWindow (before / after)Same day?Applies to crypto?Effect
AustraliaNo statutory rule. General anti-avoidance (Part IVA); wash sales covered by TR 2008/1No fixed window. Purpose testNo specific ruleYes. ATO's June 2022 release named crypto wash salesLoss denied if Part IVA applies
CanadaSuperficial loss (ITA s. 54)30 days before / 30 days after (61 days)Yes. Same-day repurchase is inside the windowYes. No crypto exemption foundLoss denied now; added to ACB of the substituted property. Requires the property to be held at end of window. Includes affiliated persons
FranceNonen/an/aNo rule existsn/a
GermanyNone for crypto or securities. Selling and rebuying shares the same day is not an abuse under §42 AO (BFH IX R 60/07)n/an/aNo rule existsn/a
IndonesiaNone foundn/an/aNo rule existsn/a. Losses give no relief anyway
IrelandFour-week rule (s.581 TCA 1997)Identification: 4 weeks before. Loss restriction: 4 weeks afterNot statedNot settled. Revenue publishes nothing for cryptoDisposal matched first to shares bought in the prior 4 weeks. Loss on shares re-bought within 4 weeks after only offsets gains on the re-bought shares. Includes spouses living together
NetherlandsNonen/an/aNo rule existsn/a. Box 3 does not tax disposals
NigeriaNone identifiedn/an/aNo rule existsn/a
SingaporeNone foundn/an/aNo rule existsn/a. Capital losses are not deductible anyway
South AfricaParagraph 42, Eighth Schedule (short-term repurchase)45 days before / 45 days afterNo separate same-day rule foundYes. Crypto assets are financial instrumentsLoss disregarded (proceeds deemed equal to base cost); loss added to base cost of the repurchased asset. Includes connected persons
SwitzerlandNonen/an/aNo rule existsn/a. Private losses are not deductible anyway
United KingdomSame-day rule (s105 TCGA 1992), then 30-day rule (s106A)None before / 30 days afterYes. Same-day matching comes firstYes. Applies to fungible tokens of the same type; NFTs excludedCost re-matched to the new acquisition. Applies to gains and losses. Not a loss deferral
United StatesWash sale (26 USC §1091)30 days before / 30 days after (61 days)YesNo. §1091 covers "stock or securities"; crypto is property. H.R. 9172 (June 2026) would extend it; not enactedLoss disallowed; added to basis of the replacement shares (securities only)

Harvesting a loss: what works where#

CountryCrypto loss realised and asset rebought immediately?Condition
AustraliaRiskyPart IVA can deny the loss where the sale's purpose is a tax benefit. No safe window
CanadaNoRebuying within 30 days and holding at day 30 denies the loss. Wait 31 days
FranceYesSale must be to fiat or goods (swaps are not taxable). Loss only offsets same-year crypto gains. Result depends on the whole-portfolio formula, not on the token sold
GermanyYesNo rule. Loss only offsets §23 gains. The rebought units start a new 1-year holding period
IndonesiaNo benefitFinal tax applies to gross value; no loss relief
IrelandNot settledDepends on whether s.581 reaches crypto
NetherlandsNo benefitBox 3 taxes a deemed or actual return, not disposals
NigeriaYesNo rule identified. 2026 loss usable only against digital-asset gains
SingaporeNo benefit (investor)Capital losses are not deductible
South AfricaNoRebuying within 45 days disregards the loss and moves it to the new base cost
SwitzerlandNo benefit (private investor)Private losses are not deductible
United KingdomNoSame-day and 30-day rules re-match the sale to the rebuy. Rebuy on day 31 or later
United StatesYes§1091 does not cover crypto held as property. Crypto ETFs are securities and are covered
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