Tax by country: comparison

Last verified	Status
28-10-2026	approved by the owner (accountant), 28-10-2026

Not tax advice. Figures are taken from each country page and summarised from official sources, linked where each rule is stated, as verified on 28-10-2026. Confirm with a qualified adviser before filing.

Scope: resident individuals investing on private (capital) account. Business traders are noted only where the rule differs.

Capital gains on crypto#

Country	How gains are taxed	Rate (current year)	Holding-period relief	Annual allowance or threshold
Australia	Net capital gain added to assessable income	2026–27: marginal 0%, 15%, 30%, 37%, 45%, plus 2% Medicare levy	50% CGT discount if held 12 months or more. Replaced from 01-07-2027 by CPI indexation and a 30% minimum tax	None for gains. AUD 18,200 tax-free threshold applies to total taxable income (0% band). Personal-use exemption only if acquired for AUD 10,000 or less and used for consumption
Canada	Half of the gain (one-half inclusion) added to income	2026: 50% of gain × federal 14% to 33%, plus provincial tax (not covered)	None	None
France	Flat tax (PFU) on occasional private disposals; progressive-scale option	31.4% = 12.8% income tax + 18.6% social contributions (2025 and 2026 income)	None	Cliff: household disposal proceeds of EUR 305 or less in the year make all gains exempt. Above that, taxable from the first euro
Germany	Private sale transaction (§23 EStG) if held one year or less	Personal progressive rate 0% to 45%	Held more than one year: gain not taxable. No 10-year extension for staked or lent tokens	Cliff: total §23 gains under EUR 1,000 in the year are tax-free; at EUR 1,000 or more the full amount is taxable
Indonesia	No gain calculation. Final income tax (PPh 22) on gross transaction value	0.21% via a domestic platform; 1% via a foreign platform (from 01-08-2025)	None	None. Tax is on every sale, gain or loss
Ireland	Capital gains tax per disposal	2026: 33% to 06-10-2026; 31% from 07-10-2026 (Finance (No. 2) Bill 2026, not enacted at 23-10-2026)	None	Allowance: EUR 1,270 of chargeable gains per individual, after losses
Netherlands	Not taxed as gains. Box 3 deemed return on net wealth at 1 January	2026: 36% on a deemed return of 6.00% on investments incl. crypto	None (no realisation basis)	Allowance on wealth, not gains: EUR 59,357 tax-free wealth per person (2026)
Nigeria	2026: gain added to total income. 2025: flat capital gains tax	2026: progressive 0% to 25%. 2025: 10%	None identified	None for crypto. First NGN 800,000 of chargeable income at 0% (2026 band)
Singapore	No capital gains tax. Gains taxable only if revenue in nature (trading, badges of trade)	Trading gains: resident rates 0% to 24% (YA 2026)	None as a rule. Holding period is one badge of trade	None. First SGD 20,000 of chargeable income at 0%
South Africa	Capital or revenue by dominant intention. Capital: 40% of net gain added to taxable income	2026/27: marginal 18% to 45%; maximum effective 18% on capital gains. Revenue: 100% at marginal rate	None for crypto. The 3-year rule for shares does not apply	Allowance: annual exclusion ZAR 50,000 (2026/27, in Bill B34-2026 as introduced), ZAR 40,000 (2025/26)
Switzerland	Private investor: tax-free. Professional trader: self-employment income	Private: 0%. Professional: federal, cantonal and communal income rates (not quoted)	None as a rate. Holding at least 6 months is one of five safe-harbour criteria for private status	Not applicable. Private gains fully exempt
United Kingdom	Capital gains tax	2026/27: 18% within unused basic-rate band, 24% above	None	Allowance: GBP 3,000 annual exempt amount
United States	Short-term at ordinary rates; long-term at preferential rates	2026: short-term 10% to 37%; long-term 0%, 15%, 20%; plus 3.8% NIIT above MAGI thresholds	Long-term rates if held more than one year	None. 0% long-term band up to USD 49,450 taxable income (single, 2026)

Swaps, spending, staking#

Country	Crypto-to-crypto taxable?	Spending taxable?	Staking taxed at receipt?	VAT/GST on buying crypto
Australia	Yes. CGT event at AUD value of crypto received	Yes. Personal-use exemption possible (see above)	Yes. Ordinary income at AUD market value	No GST. Digital currency is an input-taxed financial supply
Canada	Yes (barter)	Yes (barter)	Yes for centralized-exchange staking, when credited. Own validator and DeFi: not addressed by CRA	No GST/HST on virtual payment instruments (exempt financial service). Other crypto-assets likely taxable
France	No. Exchanges without cash balance are deferred (sursis d'imposition)	Yes	Taxed as BNC (non-commercial profits)	No VAT on fiat-to-bitcoin exchange (CJEU Hedqvist)
Germany	Yes. Disposal plus new acquisition; one-year clock restarts	Yes	Yes. Other income (§22 Nr. 3) at market value on receipt; EUR 256 cliff	No VAT. Fiat-crypto exchange is exempt (§4 Nr. 8 b UStG)
Indonesia	Yes. 0.21% final PPh 22 on each party	—	DJP says taxable, treatment not yet regulated	No VAT on crypto transfers from 01-08-2025. Platform fees: 12% on 11/12 of commission
Ireland	Yes. CGT disposal at euro value	Yes	No Revenue guidance	No VAT. Crypto-for-fiat exchange is exempt
Netherlands	No. Not a Box 3 event	No. Not a Box 3 event	No official statement on staking	No VAT on fiat-to-bitcoin exchange (CJEU Hedqvist)
Nigeria	Yes (2026)	Yes (2026). Tax on the USD gain of the token spent	Yes (2026). USD fair market value converted at CBN/NAFEM rate; 10% WHT via a VASP	No VAT on the asset. 7.5% VAT on VASP fees. 1.5% stamp duty on fiat-to-token transfers
Singapore	Only for a trader (revenue asset)	Barter. Taxable only for a trader	Not addressed by IRAS	No GST. Exchange of digital payment tokens exempt from 01-01-2020
South Africa	Yes (barter at market value)	Yes	Yes. Gross income at market value on receipt	No VAT on buying or selling (exempt financial service). Fees standard-rated at 15%
Switzerland	Private: no (gain tax-free). Professional: yes	Private: no (gain tax-free)	Yes. Income at CHF market value on receipt	No VAT on payment tokens (exempt like foreign exchange)
United Kingdom	Yes	Yes	Yes (non-trade). Miscellaneous income at GBP value on receipt	No VAT on crypto-fiat exchange
United States	Yes	Yes	Yes. Ordinary income at FMV when the taxpayer gains dominion and control	No federal VAT. State sales tax out of scope

Shares and funds#

Country	Gains rate	Dividends	Fund/ETF special regime
Australia	Same CGT regime as crypto, incl. 50% discount	Not covered on country page	Not covered on country page
Canada	Same one-half inclusion as crypto	Not covered on country page	Not covered. TFSA annual limit CAD 7,000 (2026)
France	PFU: 12.8% income tax plus social contributions	Secondary sources conflict on which income year gets 18.6%	Not covered on country page
Germany	Flat 25% (Abgeltungsteuer) plus 5.5% solidarity surcharge on the tax, plus church tax if liable. No holding-period relief	Capital income at the same 25% flat rate. Sparer-Pauschbetrag allowance EUR 1,000 single / EUR 2,000 joint	Teilfreistellung: 30% (equity funds), 15% (mixed), 60% (real-estate) of income exempt
Indonesia	Listed IDX shares: 0.1% final on gross sale value. Founder shares: extra 0.5% at listing. Other gains: progressive 5% to 35%	10% final. 0% for resident individuals if reinvested in Indonesia within the set period	—
Ireland	Same CGT rates as crypto	Not researched on country page	Gross roll-up (exit tax): 38% from 01-01-2026; 35% from 01-01-2027 (announced). Deemed disposal every 8 years. No loss relief
Netherlands	Box 3 deemed return, same as crypto	Not taxed separately under the deemed regime. 15% dividend withholding tax, creditable	None. Same Box 3 regime
Nigeria	2026: progressive 0% to 25%. Nigerian shares exempt if proceeds under NGN 150,000,000 and gain not above NGN 10,000,000 in 12 months, or if reinvested	Not covered on country page	Not covered on country page
Singapore	No capital gains tax. Same capital-vs-revenue test	Not covered on country page	Not covered on country page
South Africa	Same CGT (40% inclusion, max effective 18%). Shares held 3 years deemed capital	SA dividends: exempt from income tax, 20% dividends tax withheld. Foreign dividends: max effective 20%	Not covered. Tax-free savings: ZAR 46,000 a year (2026/27), lifetime ZAR 500,000
Switzerland	Private investor: tax-free	35% Swiss withholding tax, refundable to residents who declare. Income-tax rate cantonal, not quoted	Not covered on country page
United Kingdom	Same CGT rates as crypto (18% / 24%)	2026/27: GBP 500 allowance; 10.75% basic, 35.75% higher, 39.35% additional	Not covered. ISA allowance GBP 20,000
United States	Same short-/long-term split and rates. Wash-sale rule applies to stock and securities	Included in NIIT base. Qualified-dividend rate not covered on country page	Not covered on country page

Wealth and deemed-return taxes#

Only Netherlands and Switzerland tax holdings each year. Ireland taxes a deemed gain on funds.

Netherlands: Box 3#

Parameter	2025	2026
Valuation date	01-01-2025	01-01-2026
Deemed return, bank balances	1.37%	1.28% (provisional)
Deemed return, investments and other assets (incl. crypto)	5.88%	6.00%
Deemed return, debts	2.70%	2.70% (provisional)
Debt threshold	EUR 3,800 per person	EUR 3,800 per person
Tax-free wealth	EUR 57,684 per person	EUR 59,357 per person
Rate	36%	36%
Actual-return route	If actual return (incl. unrealised changes) is lower, tax is on actual return. No tax-free amount; negative set to EUR 0	Same
Replacement	Actual-return Box 3 adopted by Tweede Kamer 12-02-2026; target start 01-01-2028; not law	Same

Switzerland: cantonal wealth tax#

Item	Rule
Levied by	Cantons only. No federal wealth tax
Valuation date	31 December
Value	Market value. ESTV publishes tax values for common coins (Kursliste, ICTax)
Coin not in Kursliste	Market value from a leading trading platform
No price available	Original purchase price in CHF
Rate	Set by each canton. Not quoted on country page

Ireland: deemed disposal on funds#

Item	Rule
Deemed disposal	Irish and equivalent EU/EEA/OECD funds: every 8 years, at the exit-tax rate (38% in 2026)
Credit	Tax paid on a deemed disposal is credited against the actual disposal
Announced	New investment account from 01-07-2027: 1% annual tax above EUR 50,000; outside CGT, exit tax and deemed disposal. Not law

What changed in 2025–2026#

Country	Date	Change	Status
Australia	01-07-2027	50% CGT discount replaced by CPI indexation and 30% minimum tax for individuals. Gains accrued before 01-07-2027 keep the discount. Also: lowest band 16% to 15% from 01-07-2026	Law (Act No. 49 of 2026, assented 26-06-2026); apportionment rules pending
Canada	21-03-2025	Proposed two-thirds inclusion rate cancelled; rate stays one-half. Also: lowest federal rate 15% to 14% from 01-07-2025	Final
France	2025 income	Social contributions 17.2% to 18.6%; PFU 30% to 31.4%. Also: from 01-01-2026 NFTs move to art. 150 VH ter; DAC8 reporting starts	In force
Germany	06-03-2025	New BMF crypto letter replaces the 2022 letter. Also: DAC8 (KStTG) reporting from 01-01-2026	In force
Indonesia	01-08-2025	PMK 50/2025: VAT on crypto removed; final PPh 22 0.21% domestic / 1% foreign. Also: miners on general rates from tax year 2026	In force
Ireland	07-10-2026	CGT 33% to 31%. Also: fund exit tax 41% to 38% from 01-01-2026, 35% from 01-01-2027	Applied by Revenue; Finance (No. 2) Bill 2026 not enacted at 23-10-2026
Netherlands	2025	Counter-evidence (actual-return) route claimable in the return; separate crypto box. Also: Hoge Raad 25-04-2025 confirms crypto is a Box 3 asset	In force
Nigeria	01-01-2026	Nigeria Tax Act: CGT folded into income tax (10% flat to 0%–25% progressive). Also: NRS virtual-asset guidelines 31-07-2026 (1% WHT, 10% WHT on rewards, 1.5% stamp duty)	In force; guidelines have no stated effective date
Singapore	11-08-2026	CARF regulations enacted. Collection from 01-01-2027. Digital-tokens e-Tax Guide re-issued 30-01-2026 with no policy change	Law
South Africa	01-03-2026	CARF in force. Also: annual exclusion ZAR 50,000 (Budget 2026); draft crypto guide 01-07-2026; IT3(c) base cost by specific identification or FIFO 02-06-2026	CARF in force; guide is a draft
Switzerland	01-01-2026	Amended CRS covers certain crypto-assets. CARF not before 01-01-2027. No change to the private gains exemption	In force; CARF pending
United Kingdom	01-01-2026	CARF data collection by UK providers. Also: dividend rates +2 points from 06-04-2026; DeFi loans and pools no gain, no loss from 06-04-2027	In force; DeFi rule announced
United States	01-01-2025	Cost basis per wallet or account; Form 1099-DA gross proceeds. Also: rates made permanent 04-07-2025; broker basis reporting from 01-01-2026	In force

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