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.
| Last verified | Status |
|---|---|
| 28-10-2026 | approved 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#
Sell-and-rebuy rules#
| Country | Rule name | Window (before / after) | Same day? | Applies to crypto? | Effect |
|---|---|---|---|---|---|
| Australia | No statutory rule. General anti-avoidance (Part IVA); wash sales covered by TR 2008/1 | No fixed window. Purpose test | No specific rule | Yes. ATO's June 2022 release named crypto wash sales | Loss denied if Part IVA applies |
| Canada | Superficial loss (ITA s. 54) | 30 days before / 30 days after (61 days) | Yes. Same-day repurchase is inside the window | Yes. No crypto exemption found | Loss denied now; added to ACB of the substituted property. Requires the property to be held at end of window. Includes affiliated persons |
| France | None | n/a | n/a | No rule exists | n/a |
| Germany | None for crypto or securities. Selling and rebuying shares the same day is not an abuse under §42 AO (BFH IX R 60/07) | n/a | n/a | No rule exists | n/a |
| Indonesia | None found | n/a | n/a | No rule exists | n/a. Losses give no relief anyway |
| Ireland | Four-week rule (s.581 TCA 1997) | Identification: 4 weeks before. Loss restriction: 4 weeks after | Not stated | Not settled. Revenue publishes nothing for crypto | Disposal 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 |
| Netherlands | None | n/a | n/a | No rule exists | n/a. Box 3 does not tax disposals |
| Nigeria | None identified | n/a | n/a | No rule exists | n/a |
| Singapore | None found | n/a | n/a | No rule exists | n/a. Capital losses are not deductible anyway |
| South Africa | Paragraph 42, Eighth Schedule (short-term repurchase) | 45 days before / 45 days after | No separate same-day rule found | Yes. Crypto assets are financial instruments | Loss disregarded (proceeds deemed equal to base cost); loss added to base cost of the repurchased asset. Includes connected persons |
| Switzerland | None | n/a | n/a | No rule exists | n/a. Private losses are not deductible anyway |
| United Kingdom | Same-day rule (s105 TCGA 1992), then 30-day rule (s106A) | None before / 30 days after | Yes. Same-day matching comes first | Yes. Applies to fungible tokens of the same type; NFTs excluded | Cost re-matched to the new acquisition. Applies to gains and losses. Not a loss deferral |
| United States | Wash sale (26 USC §1091) | 30 days before / 30 days after (61 days) | Yes | No. §1091 covers "stock or securities"; crypto is property. H.R. 9172 (June 2026) would extend it; not enacted | Loss disallowed; added to basis of the replacement shares (securities only) |
Harvesting a loss: what works where#
| Country | Crypto loss realised and asset rebought immediately? | Condition |
|---|---|---|
| Australia | Risky | Part IVA can deny the loss where the sale's purpose is a tax benefit. No safe window |
| Canada | No | Rebuying within 30 days and holding at day 30 denies the loss. Wait 31 days |
| France | Yes | Sale 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 |
| Germany | Yes | No rule. Loss only offsets §23 gains. The rebought units start a new 1-year holding period |
| Indonesia | No benefit | Final tax applies to gross value; no loss relief |
| Ireland | Not settled | Depends on whether s.581 reaches crypto |
| Netherlands | No benefit | Box 3 taxes a deemed or actual return, not disposals |
| Nigeria | Yes | No rule identified. 2026 loss usable only against digital-asset gains |
| Singapore | No benefit (investor) | Capital losses are not deductible |
| South Africa | No | Rebuying within 45 days disregards the loss and moves it to the new base cost |
| Switzerland | No benefit (private investor) | Private losses are not deductible |
| United Kingdom | No | Same-day and 30-day rules re-match the sale to the rebuy. Rebuy on day 31 or later |
| United States | Yes | §1091 does not cover crypto held as property. Crypto ETFs are securities and are covered |
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