Crypto tax rates in Italy 2026: 26%, 33% and EMT tokens

The regulatory framework for the taxation of capital gains from crypto-assets in Italy has undergone a significant evolution. Between the end of 2024 and 2025, the legislator intervened with two distinct legislative measures that redefined the rates applicable to the substitute tax on miscellaneous income under art. 67, paragraph 1, lett. c-sexies) of the TUIR:

1. Legge di Bilancio 2025 (Legge n. 207/2024, art. 1, paragraph 24): Introduced the increase of the ordinary tax rate from 26% to 33% for transactions realized from 1 January 2026.
2. Decreto Correttivo Fiscale / Legge n. 199/2025 (art. 1, paragraph 28): Introduced a specific safeguard clause for electronic-money tokens denominated in euro (EMT compliant with the MiCA Regulation), retaining for them the reduced taxation at 26%.

This temporal layering makes it essential to distinguish precisely the moment of realization of the transaction from the tax period in which the return is filed.

How does the rate system for crypto capital gains work?

The general rule of Italian tax law for miscellaneous financial income of natural persons is the cash principle: proceeds are considered received and taxable at the moment when liquidity effectively enters the taxpayer's economic availability or the disposal is completed. In the 2026 filing model (relating to tax year 2025) and in subsequent tax windows, the applicable rates depend on two concurrent factors:

• The exact realization date of the transaction: Before or after midnight on 31 December 2025.
• The nature of the token being disposed of or held: Ordinary crypto-asset (Bitcoin, Ethereum, utility token) or electronic-money token (EMT) pegged to the euro.

Which transactions fall under the 26% rate?

The 26% rate remains in force for two main categories of transactions:

1. All capital gains realized by 31 December 2025: Regardless of when the return is filed, capital gains arising from disposals for consideration completed by the end of 2025 are subject to the ordinary 26% substitute tax. This is the amount that flows into the usual Sezione V-A of Quadro RT (Modello Redditi PF 2026) or into Quadro T of Modello 730/2026.
2. Electronic-money tokens (EMT) denominated in euro: Even from 1 January 2026 onwards, gains generated by the disposal or use of stablecoins regulated as euro EMT retain the preferential 26% rate (to be reported in the new Sezione V-A2 of Quadro RT).

When does the 33% rate take effect and how is it applied?

The rate increase to 33% enters into force for disposals and realizations carried out from 1 January 2026. This new rate covers:

• Sales into fiat currency of Bitcoin (BTC), Ethereum (ETH), Solana (SOL) and all generic altcoins.
• Transactions carried out through tokens not falling within the MiCA definition of euro-denominated EMT (including algorithmic stablecoins, reserve tokens or stablecoins denominated in foreign currencies such as USD, unless specifically transposed into law).
• Income from decentralized finance (DeFi) activities and staking protocols received from 2026 onwards.

Capital gains subject to the 33% rate will be entered in the new Sections V-A1 and V-B1 of Quadro RT and in the corresponding schedule of Modello 730/2027.

What does the special exception for Electronic Money Tokens (EMT) provide?

European Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) draws a clear distinction between electronic-money tokens (Electronic Money Tokens or EMT) and other types of digital asset. An EMT is a token that aims to maintain a stable value by referencing the value of an official legal-tender currency, acting as an electronic surrogate for fiduciary money. With art. 1, paragraph 28, of Legge n. 199/2025, the Italian legislator established that:

To benefit from this reduced 26% rate in 2026 and subsequent years, the token must meet two cumulative conditions:

1. Be issued in accordance with MiCA rules by an electronic-money institution or authorized entity.
2. Have the euro (EUR) as its primary reference value, and not third currencies (such as the US dollar) or baskets of currencies/commodities.

Capital gains on euro-pegged stablecoins must be monitored and reported separately in the specific Sezione V-A2 of Quadro RT.

How the cash principle applies: realization date vs filing year

Determining the correct rate requires careful consideration of the cash principle against the temporal sequence of transactions:

1. Reconciliation based on the order date: It is the execution date of the transaction that determines the applicable rate, not the year in which the filing model is completed. A sale made in December 2025 and reported in spring/autumn 2026 is taxed at 26%; a sale executed in January 2026 will be taxed at 33% (or 26% if euro EMT) in the return filed in 2027.
2. Parallel asset monitoring: The Imposta sul Valore delle Cripto-Attività (IVCA) in Quadro RW remains stably at 2 per thousand (0.2%) per year on the final holding value, remaining entirely independent of capital-gain rates.
3. Tracking the nature of tokens: For sales executed from 2026 onwards, it is advisable to record accurately the classification of each stablecoin (euro EMT vs dollar tokens or other denominations), so as to apply the correct settlement rate.

Summary framework of rates for the return

Practical aspects to consider for correct settlement

To set up calculations correctly ahead of the next filing obligations, it is useful to consider the following steps:

1. Clearly separate tax periods: The 33% rate has no retroactive effect on tax year 2025. For transactions concluded by 31 December 2025, the 26% rate continues to apply.
2. Catalogue stablecoin holdings: Anyone holding positions in various stablecoins should verify the asset classification under MiCA, distinguishing euro-denominated tokens (for which the 26% safeguard applies) from those denominated in dollars or other currencies.
3. Consolidate supporting evidence: Retain for each disposal the exact transaction timestamp, the euro countervalue at the official Banca d'Italia exchange rate and the analytical report issued by the intermediary.

Official Agenzia delle Entrate sources

• Circolare n. 30/E del 27 ottobre 2023 (PDF AdE) — Tax treatment of capital gains under art. 67 TUIR and ordinary rate at 26%.
• Infoprecompilata — Quadro RT (AdE) — Specifications on sections V-A (26%), V-A1 (33%) and V-A2 (euro EMT tokens at 26%).
• Infoprecompilata — Quadro T (730) — Reporting of capital income and miscellaneous financial income in Modello 730.
• Istruzioni Redditi Persone Fisiche 2026 — Fascicolo 2 (PDF AdE) — Instructions for settlement of the substitute tax in Quadro RT.
• Istruzioni Modello 730/2026 (PDF AdE) — Instructions for completing financial schedules with withholding-agent adjustment.