Global exchange of information on crypto-asset transactions to tax authorities about to come – urgent need for action for crypto investors

New global OECD rules will require crypto platforms to report all transactions of their customers. This will enable tax authorities to verify whether investors have properly declared their crypto-asset income. With the Austrian Crypto Reporting Obligations Act (Krypto-MPfG), the government draft of which was published on 20 November 2025, Austria is implementing the new rules through its own national legislation. Starting from 1 January 2026, crypto platforms must comply with the reporting obligations. The first customer data will then be transmitted to the tax authorities in 2027. Investors who have not yet declared their income from cryptocurrency holdings should act quickly to avoid financial criminal consequences. Once the tax authorities have access to the transaction data, substantial penalties cannot be ruled out.

Cryptocurrencies such as Bitcoin, Ethereum or Solana have established themselves over the past few years as a serious alternative to traditional financial assets. Along with their growing popularity among investors, cryptocurrencies have increasingly become the focus of legislation. In Austria, separate regulations for the taxation of cryptocurrencies were introduced three years ago, which eliminated uncertainties and created legal certainty. Since the reform in 2022, income from cryptocurrency holdings is generally subject to a special tax rate of 27.5%, just like all other income from capital assets.

Dangerous misunderstanding regarding foreign crypto exchanges

Since 1 January 2024, Austrian crypto platforms are required to withhold the 27.5% tax on income from cryptocurrency holdings in and remit it to the tax authorities on behalf of the investors. It is possible that Austrian investors deliberately avoid Austrian crypto exchanges and instead use foreign crypto exchanges to circumvent the KESt deduction. However, using a foreign crypto exchange does not mean that the income is tax-free simply because there is no Austrian withholding tax deduction. Investors who use foreign crypto exchanges are therefore obliged to declare their cryptocurrency income in their tax returns. Various studies show that a large proportion of investors fail to comply with these obligations.

New OECD rules make crypto-asset transactions cross-border accessible

Crypto-asset transactions conducted through Austrian and foreign crypto exchanges are currently not accessible to Austrian tax authorities. This is set to change with the revised EU Directive on Administrative Cooperation (known as DAC 8), which is based on the OECD’s Crypto-Asset Reporting Framework (CARF) and is being implemented in Austria through the Austrian Crypto Reporting Obligations Act (Krypto-MPfG). The government draft for the Krypto-MPfG was published on 20 November 2025. DAC 8 requires crypto-asset service providers to report the name, address, and tax identification number of taxpayers, as well as the crypto-asset transactions conducted, to the tax authorities. Therefore, if Austrian investors execute their crypto-asset transactions via a crypto exchange in Germany, for example, the German crypto exchange reports the transactions of the Austrian investors to the German tax authority, which in turn forwards the data to the Austrian tax authorities. As a result, the Austrian tax authorities will receive comprehensive data on taxpayers’ crypto-asset transactions, which can be processed with automation support and used to verify the tax compliance of investors.

CARF is not only being implemented by EU member states. More than 40 non-EU countries have also committed to participate. DAC 8 comes into effect in the EU on 1 January 2026, with the first reports to the tax authorities for the year 2026 to be submitted in 2027.

Timely voluntary disclosure can prevent financial criminal proceedings

As the risk of detection will significantly increase with international data exchange, investors who have so far been delinquent are advised to subsequently tax their improperly declared cryptocurrency income as soon as possible through a voluntary disclosure. A voluntary disclosure can only prevent penalty under certain conditions – particularly if the tax authority has not yet initiated investigative measures at the time of disclosure, or if the investors are not aware that the offense has already been partly or fully detected. Even if the tax authorities have already become aware of undeclared income from cryptocurrency holdings, submitting a voluntary disclosure is generally advisable, as it may serve as a mitigating factor.

Regardless, a voluntary disclosure must meet substantive requirements. For example, the misconduct must be explained, and the circumstances relevant to determining the tax understatement must be fully disclosed. The general tax limitation period is five years, and in cases involving (conditional) intent (tax evasion), ten years. For income from capital assets (including cryptocurrencies), conditional intent is generally assumed. Given the complexity of these provisions, it is strongly recommended to seek professional assistance.

Challenge of data collection

The accurate calculation of tax on income from cryptocurrency holdings requires records of transactions that are as complete as possible. This is particularly challenging when a wide variety of different transactions are conducted (ranging from cryptocurrency swaps to staking, mining, lending, and margin trading), trading takes place across multiple crypto exchanges, and crypto-assets are transferred into personal wallets. Our blockchain and tax experts at PwC have the expertise needed to successfully address these challenges.