Redditi Diversi (Italy)
In Italian personal income tax law, redditi diversi (miscellaneous income) is a statutory income category codified under Article 67 of the Italian Income Tax Consolidation Act (TUIR) that governs capital gains derived from non-business financial and speculative activities. Since January 1, 2023, all income, capital gains, and holding proceeds generated from crypto-assets by Italian tax residents are formally classified under Article 67, paragraph 1, letter c-sexies of the TUIR.
Historical evolution of crypto classification in Italy
The tax treatment of cryptocurrency in Italy underwent a major structural reform with the 2023 Budget Law:
| Tax Era | Statutory Classification and Regime |
|---|---|
| Pre-2023 Regime (Letter c-ter) | Cryptocurrencies were assimilated to foreign currencies; capital gains were only taxable if total portfolio holdings exceeded €51,645.69 for at least 7 consecutive business days |
| Post-2023 Regime (Letter c-sexies) | Creation of an autonomous cripto-attività category; all realized capital gains subject to substitute tax via LIFO lot matching |
| Statutory Scope | Encompasses capital gains, staking rewards, lending yields, and gains from transactions with unequal characteristics |
Key tax mechanics of letter c-sexies
Classifying crypto under the redditi diversi framework establishes specific procedural rules:
- Substitute tax regime: Income is taxed via a proportional imposta sostitutiva rather than through progressive personal income tax (IRPEF) brackets.
- Horizontal loss offsetting: Capital losses realized within letter c-sexies directly offset capital gains of the same category, with unused net losses eligible for a 4-year carry-forward.
- Internal ring-fencing: Crypto capital losses cannot offset capital gains from traditional financial instruments (such as equities or bonds) governed by other sub-clauses of Article 67.
For practical calculation and tax declaration rules under Italian tax residency, see our dedicated guides on Calculating Capital Gains and Cost Basis and the Italian Crypto Tax Return Guide.
The information in this article is for general literacy only. It is not tax, legal, financial, or accounting advice and does not replace Agenzia delle Entrate instructions or advice from a qualified professional for your circumstances. It must not be used to evade tax obligations. We make no warranty as to accuracy, completeness, or currency; rules and practice can change. Do not file returns or make decisions based solely on this text. RIXTO is not liable for loss arising from use of, or reliance on, this information.