Cryptocurrencies and Hacienda: the tax report and how to reply to a request

As long as you only buy and hold cryptocurrencies, you do not pay income tax. The tax applies when you sell them for euros, exchange them for another cryptocurrency or pay with them: at that moment a capital gain or loss occurs, which is the difference between the transfer value and the acquisition value, including the commissions you have paid in each transaction.

These gains and losses go to the savings base of your tax return, which in the 2025 financial year (declared in 2026) is taxed between 19% and 30% in brackets. They are declared in the specific virtual currencies section of form 100 (boxes 1800 onwards).

When you sell a portion of your coins bought at different times, the law applies the FIFO method: the first ones you bought are considered sold. Furthermore, according to the criteria of the Directorate General for Taxation, FIFO is global for each type of cryptocurrency, consolidating all your exchanges and wallets, not account by account. That is why a calculation done exchange by exchange usually turns out wrong.

Losses are also declared: they are offset against other savings gains and, the excess, against income from movable capital up to a certain limit; whatever is left over can be offset in the following 4 financial years, but only if it was declared. Managora consolidates all your movements with global FIFO and gives you the report with the result and the exact boxes: you can see the updated amount in the cryptocurrency tax report file.

Yes, and it is the most frequent mistake made by investors. Exchanging one cryptocurrency for another (a swap, for example from Bitcoin to Ethereum or to a stablecoin) is an exchange and generates a capital gain or loss even if it has not been converted to euros. The AEAT tax return manual confirms this: the transaction is valued at the higher of the market value of the coin delivered and the one received.

Staking and lending rewards are not capital gains: they are taxed as income from movable capital in the savings base, valued in euros at the time you receive them, according to the criteria of the Directorate General for Taxation.

Airdrops (coins received for free) are taxed as a capital gain that does not derive from a transfer, so they go to the general base (the one with the highest rates), valued at market price on the date of receipt.

Paying for goods or services with cryptocurrencies is also a transfer and is taxed in the same way as a sale. Managora applies all these nuances in your report: you only provide the CSV files from your exchanges and the history of your wallets.

You do not submit forms 172 (balances) and 173 (transactions): they are submitted every January by cryptocurrency service providers established in Spain (exchanges and custodians), under the Orden HFP/887/2023 (Order HFP/887/2023). This means that Hacienda already receives your balances and your transactions on Spanish platforms every year, along with your identification.

Form 721 is your obligation: if on 31 December the combined value of your virtual currencies located abroad and custodied by third parties exceeds €50,000, you must submit it between 1 January and 31 March of the following year. In subsequent years it is only submitted again if the balance grew by more than €20,000 compared to the last declaration.

The form 721 obligation refers to coins custodied by entities that safeguard the private keys for you (a foreign exchange, for example). If you alone custody the keys in your own cold wallet, that nuance changes the obligation: it is advisable to review it on a case-by-case basis because the doctrine of the Directorate General for Taxation is recent.

From 1 January 2026, the European DAC8 directive also applies: crypto-asset providers across the EU collect data from their users and in 2027 the first automatic exchange between administrations will take place with the 2026 information. The opacity of foreign exchanges has an expiry date.

Because the AEAT cross-references data. It receives forms 172 and 173 from Spanish exchanges, the bank information of your transfers to platforms, data from massive requests to operators and, from 2026, the DAC8 flow. If that data does not match your tax return (or if you did not submit a tax return with detected transactions), the warning is triggered.

Not all letters are the same. It can be a simple warning in your tax data, a request for information asking for the details of transactions, or the start of an inspection (sometimes already with a settlement proposal). Identifying which one it is determines the response strategy.

Ignoring the request is the worst option: disregarding it can be penalised with increasing fines for each ignored request and, furthermore, the procedure continues and Hacienda will settle with the data it already has, usually without considering your acquisition costs or your losses. Managora analyses the notification and prepares the reply: you can see the updated amount in the AEAT request reply file.

The usual deadline is 10 working days counted from the day following the notification (requests for information grant a period of no less than 10 days, article 55 of the Reglamento aprobado por RD 1065/2007 (Regulation approved by RD 1065/2007)). Saturdays, Sundays and public holidays do not count. Be careful with electronic notifications: if you do not access them, they are considered served 10 calendar days after being available, and the deadline runs anyway.

If you cannot make it on time, an extension of up to half the period can be requested, asking for it before the 3 days prior to the expiration and justifying the reason. It is not automatic, but in cryptocurrency matters with thousands of movements it is usually justified.

A good reply is not a generic document: it is the complete breakdown of transactions with their traceability (purchases, sales, swaps, staking, commissions), the global FIFO calculation per asset, the CSV files from the exchanges and the bank receipts that connect your euros with your cryptocurrencies. It is submitted through the AEAT electronic headquarters using the secure verification code or reference number that appears on the notification itself.

Managora does exactly that: it reconstructs the traceability of your transactions, drafts the formal reply and submits it within the notification deadline, provided you supply the documentation sufficiently in advance. If it detects differences with what was declared, it proposes the regularisation that minimises the cost.

If you detect that you did not declare (or under-declared) your cryptocurrencies and Hacienda has not sent you anything yet, the correct move is to get ahead with a late complementary self-assessment. In that case there is no penalty: only the surcharge of article 27 of the Ley General Tributaria (General Tax Law) applies (1% plus another 1% for each full month of delay, with a maximum of 15% plus interest after 12 months), and that surcharge is reduced by 25% if you pay on time and do not appeal.

If the request has already arrived and refers to that tax and financial year, the scenario changes: the regularisation no longer counts as spontaneous and a penalty file can be opened, with fines of between 50% and 150% of the unpaid amount according to the Ley General Tributaria (General Tax Law). Even so, fully regularising and collaborating is still what costs the least: there are significant reductions in the penalty for agreement and for prompt payment.

The complementary return can be submitted as long as the financial year has not prescribed (4 years, in general) and always before the Administration issues its own settlement. As of the date of this guide, the 2025 tax return campaign has already closed (it ended on 30 June 2026), so any undeclared 2025 transaction can only be regularised this way now.

Do not wait for the letter to turn into a settlement and penalty. Order your cryptocurrency tax report or the reply to your request as soon as possible: Managora prepares and submits it for you, with the breakdown that Hacienda expects and within the deadline set by the notification, provided it receives your documentation with the necessary advance notice.