Crypto capital gains in Italy: cost and calculation

Determining the taxable income arising from crypto-asset transactions is one of the most delicate steps when completing an Italian tax return. The cornerstone rule, set out in art. 68, paragraph 9-bis of the Testo Unico delle Imposte sui Redditi (TUIR), provides that the capital gain is the difference between the consideration received (or the normal value of the assets disposed of) and the documented purchase cost or value. If the taxpayer is unable to provide suitable documentation certifying the cost originally incurred, the law applies a strict presumption: the purchase cost is deemed equal to zero, turning the entire sale proceeds into a capital gain taxable at 26% (or at 33% from 2026).

What is the general formula for calculating the capital gain?

Under art. 68 of the TUIR and the guidance in Circolare n. 30/E of the Agenzia delle Entrate (§ 3.2), the fundamental formula for each individual disposal for consideration is as follows:

Where:

• Disposal consideration: The actual countervalue in euro received from the sale of the token (or the normal value of the asset at the time of the exchange for goods or services).
• Documented purchase cost: The sum spent in euro to acquire the specific quantity of cryptocurrency being disposed of, supported by suitable documentation.

If the result of the calculation is positive, there is a taxable capital gain; if it is negative, a capital loss arises that can be used for offsetting.

How is the tax-relevant purchase cost determined?

The purchase cost must be proven with certain and precise elements (art. 68, paragraph 9-bis of the TUIR). Depending on how the asset entered the taxpayer's possession, determination follows specific criteria:

1. Acquisition for consideration (with euro or other fiat currency): The tax carrying cost corresponds to the price actually paid to purchase the assets disposed of, net of the commissions charged by the platform (exchange commissions do not increase the tax-recognised cost).
2. Crypto-assets received by donation: The tax carrying value corresponds to the cost originally incurred by the donor, increased by any gift tax paid (continuity-of-values principle).
3. Crypto-assets received by inheritance: The cost is taken as equal to the value declared for inheritance-tax purposes.
4. Tokens originating from an airdrop or hard fork: If the allocation was free of charge with no obligation of counter-performance or investment, the initial tax carrying cost is conventionally zero, unless the proceeds were already taxed at the time of receipt.

Are trading commissions and transaction fees deductible?

In generic tax calculators and international software, commissions paid to trading platforms or blockchain transfer fees are frequently subtracted from profits or added to the purchase cost. Under the Italian tax regime, however, the rules are different and more restrictive. Art. 68, paragraph 9-bis of the TUIR states expressly that capital gains are the difference between the consideration received (or the normal value) and the documented purchase cost or value. Unlike the rules for other types of financial assets (such as ordinary shareholdings under paragraph 6 of art. 68), the legislator did not introduce for crypto-assets the option to increase the purchase cost by ancillary charges or to deduct costs inherent in the disposal. The Agenzia delle Entrate, in Circolare n. 30/E of 27 October 2023 (p. 50), confirmed this interpretative line with two binding principles:

1. Purchase commissions: must be excluded from the purchase cost. The provision does not allow increasing the tax carrying cost by including commissions or fees paid to the intermediary at the time of the order.
2. Sale commissions: must be included in the consideration. Paragraph 9-bis does not allow deduction of costs inherent in the disposal: the realization consideration to be reported for tax purposes is the gross contractual amount, without deducting the portion withheld by the platform.

In practical terms, commissions withheld by exchanges do not reduce the taxable base. Applying deductions not permitted for trading commissions exposes the taxpayer to the risk of adjustments in the event of a check on Quadro RT (rows RT41 and RT42).

What does the law provide on the accounting movement method?

When an investor makes multiple purchases of the same cryptocurrency at different times and prices (for example through a dollar-cost averaging plan or periodic purchases), the question arises of which specific lot is disposed of on a partial sale. In the Italian legislative and practice landscape, two approaches coexist depending on the regime applied:

• Declarative regime (taxpayer self-management): Art. 68, paragraph 9-bis of the TUIR does not impose a single mandatory algorithm on pain of nullity. The fundamental obligation is documented and continuous traceability of lots with certain and verifiable elements. Many software applications conventionally apply the LIFO (Last-In, First-Out) criterion borrowed from art. 67, paragraph 1-bis for foreign currencies, or the specific cost of each wallet.
• Administered savings regime (authorized intermediaries): With Risposta a interpello n. 135 of 12 June 2025, the Agenzia delle Entrate clarified that Italian financial intermediaries applying the substitute tax under the administered savings regime must adopt the Weighted Average Cost (CMP) method for managing client positions.

When filing a personal return under the declarative regime, the taxpayer's absolute priority is to maintain methodological consistency across tax years and to ensure the absolute integrity of supporting reports.

What documents are needed to prove historical cost?

The burden of proving the purchase cost rests entirely on the taxpayer. In the event of a tax audit by the Agenzia delle Entrate or the Guardia di Finanza, it is necessary to be able to produce:

• Bank statements and accounting records proving wire transfers or card payments sent to trading platforms.
• Complete historical transaction logs (CSV files or certified API exports) issued by each exchange, containing date, exact time (timestamp), token quantity, unit price and fiat countervalue.
• Identifying hashes of on-chain transactions (txid) recorded on distributed ledgers (blockchains) to prove transfers between personal wallets and deposit addresses.

If a history is lost or an exchange fails without releasing reports, the tax administration disallows the carrying cost and applies full taxation on the sale countervalue (zero cost).

Practical numerical example of capital-gain calculation

Imagine the following sequence of transactions for year 2025:

1. Purchase 1: 0.5 BTC purchased in January for €20,000 (with €30 of commissions charged by the exchange). For tax purposes, the recognised carrying cost is €20,000 (unit cost: €40,000/BTC, without including the commission).
2. Purchase 2: 0.5 BTC purchased in June for €25,000 (with €30 of commissions). The recognised carrying cost is €25,000 (unit cost: €50,000/BTC).
3. Sale: 0.4 BTC sold in November for gross consideration of €30,000 (with €50 of commission withheld by the exchange).

If the LIFO method is applied, the units relating to the most recent purchase (Purchase 2) are treated as sold:

• Purchase cost for 0.4 BTC (Quadro RT, row RT42): 0.4 × €50,000 = €20,000 (the purchase commission does not increase the tax cost).
• Disposal consideration (Quadro RT, row RT41): €30,000 (the sale commission is not deducted; the gross consideration is used).
• Net taxable capital gain: €30,000 − €20,000 = €10,000

On that amount of €10,000, substitute tax at 26% will be settled in Quadro RT (or Quadro T of the 730), equal to €2,600.00.

Official Agenzia delle Entrate sources

• Circolare n. 30/E del 27 ottobre 2023 (PDF AdE) — Determination of capital gains under art. 67 TUIR, burden of proof of purchase cost and non-deductibility of commissions (§3.1, §3.2, p. 50).
• Risposta a interpello n. 135 del 12 giugno 2025 (PDF AdE) — Application of weighted average cost under the administered savings regime.
• Infoprecompilata — Quadro RT (AdE) — Completion of Sezione V-A and offsetting of capital losses in Modello Redditi PF.
• Infoprecompilata — Quadro T (730) — Reporting of financial income and capital gains in Modello 730.
• Istruzioni Fascicolo 2 — Modello Redditi PF 2026 (PDF AdE) — Technical specifications on documented cost and completion of Quadro RT.
• Istruzioni Modello 730/2026 (PDF AdE) — Technical specifications for reporting financial income in Modello 730.