Tax on Crypto in 2026: How Six Countries Compare

Short answer: In 2026, every major tax system taxes crypto when you dispose of it (sell, swap, spend or gift) and taxes crypto you earn, such as staking rewards, as income. What changes by country is the relief: the US and Australia reward holding past one year, Germany exempts private sales held over a year, and the UK and South Africa give an annual allowance.

This guide sets out how tax on crypto works in six countries our readers file in: the United States, the United Kingdom, Canada, Australia, South Africa and Germany. Each section links to the tax authority's own page, and each figure is read from that page. Where we have a full country guide, the section links to it for the detail.

What "Tax on Crypto" Means in 2026

Almost every tax authority looks at crypto through two lenses. The first is a disposal: you give up a token and something comes back, whether cash, another token, goods or nothing at all (a gift). A disposal produces a gain or a loss, measured against what the token cost you. The second is receipt as income: you get tokens for doing something, such as staking, mining, lending or working. The value at the time you receive them is income, and that value then becomes your cost for the later disposal.

The two lenses explain why a single token can be taxed twice without being taxed on the same money twice. A staking reward is income when it lands. If it later rises in value and you sell it, only the rise is a gain. HMRC says this directly: if you have paid Income Tax on part of a token's value, you will not pay Capital Gains Tax on that amount, only on the gain after you received it (HMRC, check if you need to pay tax when you sell cryptoassets).

Is buying crypto taxed?

No country in this guide taxes the purchase of crypto with cash. HMRC puts it plainly: if you bought the tokens yourself, you do not pay tax when you buy them, but you may when you sell them (HMRC, check if you need to pay tax when you receive cryptoassets). Buying is the moment your cost basis starts, so the purchase record matters even though no tax is due.

Is moving crypto between my own wallets taxed?

Generally no. The Canada Revenue Agency lists a transfer between wallets you own as a transaction that does not result in a taxable disposition (CRA, income from crypto-asset transactions). The same logic runs through the other systems: you still own the token, so nothing has been disposed of. The practical risk is that exchanges report the outgoing transfer without knowing it went to you, so your records need to show both ends.

Which events count as a disposal?

The lists line up closely across countries. The ATO, for example, names selling, gifting, swapping for another crypto asset, converting to Australian or foreign currency, and buying goods or services (ATO, crypto asset transactions). HMRC's list is selling, exchanging for a different cryptoasset, paying for goods or services, and giving tokens away, other than to a spouse, civil partner or charity (HMRC). Our guide to crypto taxable events covers the US list event by event.

United States: Crypto Is Property, With Two Holding Periods

For US tax purposes, digital assets are property, not currency (IRS, digital assets). Every disposal is a capital transaction measured against your basis, and every receipt for services or as a reward is ordinary income. The US is also the country where reporting has changed most: brokers now issue Form 1099-DA, and our guide to reading Form 1099-DA box by box explains what each figure means.

What is the difference between short-term and long-term crypto gains?

The IRS classifies a gain as long-term if you held the asset for more than one year before disposing of it, and short-term if you held it one year or less (IRS Topic 409, capital gains and losses). Short-term gains are taxed at your ordinary income rates. Long-term gains may qualify for a lower rate than the one that applies to your ordinary income, per the same IRS page.

What are the long-term capital gains rates?

For taxable years beginning in 2025, the IRS says the rate on most net capital gain is no higher than 15% for most individuals. A 0% rate applies if taxable income is at or below $48,350 for single filers and married filing separately, or $96,700 for married filing jointly. A 20% rate applies to the extent taxable income exceeds the 15% thresholds (IRS Topic 409). Check the same page for the thresholds for the year you are filing.

Are staking rewards taxed in the US?

Yes. Revenue Ruling 2023-14 holds that a cash-method taxpayer who receives staking rewards includes their fair market value in gross income in the taxable year the taxpayer gains dominion and control of them (IRS, Rev. Rul. 2023-14). Our guide to crypto staking taxes covers how to report them.

Do I have to answer the digital asset question?

Yes. Federal income tax returns ask every filer to answer "Yes" or "No" to whether, at any time during the year, they received a digital asset as a reward, award or payment, or sold, exchanged or otherwise disposed of one (IRS, digital assets). Holding crypto you bought with cash, with no other activity, is not on that list.

Where do US crypto gains go on the return?

Each disposal is listed on Form 8949 and the totals carry to Schedule D. Our guide to Form 8949 and Schedule D for crypto walks through the boxes, and how crypto is taxed in the US covers rates, income and losses in more depth.

United Kingdom: Capital Gains Tax With a Shared Pool

HMRC treats a disposal of cryptoasset tokens as a Capital Gains Tax event, and tokens received from employment, mining, staking or lending as income (HMRC, selling cryptoassets; HMRC, receiving cryptoassets). The UK tax year runs from 6 April to 5 April, per HMRC's selling guidance. Our UK crypto tax guide has the full detail on pooling.

What is the UK Capital Gains Tax allowance for crypto?

You only pay Capital Gains Tax on your overall gains above the tax-free allowance, called the Annual Exempt Amount, which GOV.UK lists as £3,000 (GOV.UK, Capital Gains Tax allowances). If your total gains for the year are above it, HMRC says you must report the gain and pay the tax (HMRC).

What Capital Gains Tax rate applies to crypto in the UK?

For gains from 6 April 2026, a higher or additional rate taxpayer pays 24%. A basic rate taxpayer pays 18% on the part of the gain that falls within the basic Income Tax band once added to taxable income, and 24% on the rest (GOV.UK, Capital Gains Tax rates).

How does pooling work for crypto in the UK?

You group each type of token into a pool and track the pooled cost. Each purchase adds to the pool; each disposal deducts a proportion of the pooled cost. HMRC's own example: 100 tokens at £2 and 300 at £1 give 400 tokens costing £500, an average of £1.25, so selling 200 uses a cost of £250 (HMRC). The calculation is different if you sell tokens within 30 days of buying them, and for same-day purchases, per the same page.

How is UK staking income taxed?

If you receive tokens from mining, staking or lending, including DeFi, and are not carrying on a trade, HMRC treats them as other taxable income. You can get up to £1,000 a year for trading and miscellaneous income, and HMRC sets reporting steps for amounts between £1,000 and £2,500 and over £2,500 (HMRC, receiving cryptoassets).

Is there a crypto section on the UK tax return?

Yes. HMRC records that Self Assessment returns include a cryptoasset section from the 2024 to 2025 tax year onwards (HMRC, page update of 29 May 2025).

Canada: Capital Gain or Business Income

The CRA says that when you dispose of a crypto-asset, the result may be business income or a capital gain, and you must report whichever applies (CRA, income from crypto-asset transactions). That split matters more in Canada than almost anywhere else, because the two are taxed very differently. Our Canadian crypto tax guide covers both, along with holding companies.

What counts as a disposition of crypto in Canada?

The CRA lists trading or exchanging a crypto-asset for government-issued currency or another crypto-asset, using it to buy goods or services, and transferring ownership by gift or donation (CRA). A transfer between wallets you own is not a taxable disposition, per the same page.

How much of a crypto capital gain is taxed in Canada?

Only part of a capital gain is taxed. The portion is set by the inclusion rate, and the CRA's 2025 capital gains guide (T4037) lists an inclusion rate of one half (50%) for 2001 to 2025 (CRA, T4037 Capital Gains 2025). Taxable capital gains are calculated on Schedule 3, per the same guide. Business income, by contrast, is fully included.

When is crypto business income in Canada?

The CRA says income from crypto-asset transactions may be business income when the activity is consistent with carrying on a business (CRA). The CRA's page sets out the factors it looks at. It is a question of fact for each person, settled at filing with your own advisor.

Are staking rewards taxed in Canada?

Yes. The CRA says rewards from staking on a centralized crypto-asset exchange platform will generally be income under the Income Tax Act at the time they are credited to your wallet on the platform (CRA, mining and staking income).

Australia: CGT With a 12-Month Discount

The ATO says a CGT event happens when you dispose of a crypto asset, and you may make a capital gain or capital loss (ATO, crypto asset transactions). Values are converted to Australian dollars, and the ATO has used Reserve Bank of Australia exchange rates since 1 January 2020, per the same page. Our guide for Australian crypto traders goes further into trading activity.

How does the CGT discount work for crypto in Australia?

You can reduce a capital gain by 50% if you owned the asset for at least 12 months and you are an Australian resident for tax purposes. The 12 months are counted excluding the day of acquisition and the day of the CGT event. Companies cannot use the discount (ATO, CGT discount).

Did the 2026-27 Budget change crypto CGT in Australia?

The ATO's discount page carries a notice that recent changes to CGT announced in the 2026-27 Federal Budget do not apply to Tax Time 2026 (ATO, CGT discount). For returns being lodged now, the discount rules above are the ones that apply.

Are staking rewards taxed in Australia?

Yes. The ATO says the money value of additional tokens received as a staking reward is ordinary income at the time you receive them, declared as other income in your tax return (ATO, staking rewards and airdrops).

Does the ATO see crypto transactions?

The ATO runs a crypto asset data-matching program that matches what you report against transaction and account data from designated service providers (ATO). Our guide on whether the ATO can track crypto explains what that means for you.

South Africa: Normal Tax Rules, Revenue or Capital

SARS says normal income tax rules apply to crypto assets, and taxpayers must declare crypto gains or losses as part of their taxable income in the tax year in which they are received or accrued. Failure to do so could result in interest and penalties (SARS, crypto assets and tax). Our South Africa crypto tax guide covers SARS returns in full.

Is crypto taxed as income or capital gains in South Africa?

Either, depending on the facts. SARS says crypto gains can be taxed on revenue account under gross income, or regarded as capital under the Eighth Schedule and taxed as capital gains, and that the question is tested under existing case law (SARS). The answer turns on your intention and the surrounding facts, so it is settled at filing by you and your tax practitioner.

What is the CGT rate and exclusion in South Africa?

SARS's capital gains tax table lists 18% for individuals and special trusts for the 2027 year, and an annual exclusion of R50,000 of capital gain or loss for individuals and special trusts (SARS, Capital Gains Tax rates). The same page lists sale, donation, exchange, loss, death and emigration among the events that trigger a disposal.

How does SARS treat mining and crypto barter?

SARS groups crypto gains into three scenarios: crypto acquired through mining, crypto exchanged for local currency on exchanges or privately, and goods or services exchanged for crypto. The last is a barter transaction, and the normal barter rules apply (SARS).

Germany: Tax-Free After One Year

Germany taxes private sales under section 23 of the Income Tax Act (EStG). A private sale of an asset other than land is a taxable private sale transaction only where the period between acquisition and sale is not more than one year (section 23 EStG). Our Germany crypto tax guide explains how this applies to tokens and to staking.

Is there a tax-free amount for crypto gains in Germany?

Yes, but it works as a threshold, not an allowance. Section 23(3) EStG says gains stay tax-free if the total gain from private sale transactions in the calendar year was less than €1,000 (section 23 EStG). Once the total reaches €1,000, the whole gain is taxable, not only the excess.

How is other crypto income treated in Germany?

Income from other services under section 22 No. 3 EStG is not taxable if it was less than €256 in the calendar year (section 22 EStG). Our Germany guide covers which crypto receipts fall under that rule.

How the Six Countries Compare

The table puts the main rules side by side. Each cell comes from the authority pages linked in the sections above.

What Triggers Tax Everywhere

Across the six countries, the same handful of events creates a tax result. Planning around them is the most useful thing a crypto holder can do.

Is a crypto-to-crypto swap taxed in every country?

In all six, yes. Swapping one token for another is a disposal of the first token: the ATO names it (ATO), HMRC names exchanging for a different cryptoasset (HMRC), and the CRA names exchanging for another crypto-asset (CRA). Our guide on whether a crypto-to-crypto swap is taxable covers the US position.

Is spending crypto taxed?

Yes. Paying for goods or services with crypto is a disposal in the UK, Canada and Australia, per the pages above, and SARS treats an exchange of goods or services for crypto as barter (SARS). A small purchase can produce a small gain, and every one counts.

Is giving crypto away taxed?

Often, yes. A gift is a disposal in Australia and Canada, and in the UK unless it goes to a spouse, civil partner or charity (HMRC). SARS lists donation as a disposal event (SARS).

Records Every Tax Authority Expects

The rules differ, but the records do not. Every calculation above needs the same four facts for each token: when you got it, what it cost in your home currency, when you disposed of it, and what you received. Crypto makes that hard because the facts are spread across exchanges, wallets and chains, and an exchange only sees its own part.

What should I keep for each crypto transaction?

Keep the date, the token and amount, the value in your home currency at that moment, what the transaction was for, and the wallet addresses on both sides. Australia values every transaction in Australian dollars, using Reserve Bank of Australia rates since 1 January 2020 (ATO). Our crypto record keeping guide sets out a working system.

What if my cost basis is missing?

Missing basis is the most common reason a crypto return overstates tax. When a token moved in from another wallet, the exchange that sells it does not know what you paid. The fix is to trace the token back to its purchase across your own records. Our guide on missing or inaccurate crypto transaction data explains how.

Do crypto exchanges report to tax authorities?

Increasingly, yes. In the US, brokers issue Form 1099-DA for digital asset sales, which is why the IRS asks every filer the digital asset question (IRS). The ATO matches returns against data from designated service providers (ATO). SARS says the Income Tax Act gives it wide collection powers, including a requirement for third-party service providers to submit financial data (SARS). An exchange report shows what happened on that exchange, not your full cost basis, so your own records still decide the figure on your return. Our guide on whether the IRS can track crypto covers the US side.

When To Get Help

Most people with one exchange and a few sales can work through the rules above with good software. Help is worth paying for when the records are the hard part: many wallets, DeFi, staking across chains, a move between countries, or years of history that never tied out. That is the work our crypto tax accountants do: rebuild the full history, match transfers between your own wallets, trace cost basis, check balances against what each wallet holds, and hand you a report for your return or for your own accountant or CPA. If you live in one of the countries above, see our crypto tax-free countries guide for the places that do not tax crypto at all.

What if I moved country during the year?

Each country taxes you under its own residence rules for its own period, and an exit can itself be a disposal: SARS lists emigration among the events that trigger a disposal (SARS). A move needs each country's rules applied to the right part of the year, which is where professional help earns its cost. Our crypto tax accountants prepare the records each side needs.