Italy: crypto taxes when leaving Germany

• Disposals: Substitute tax (imposta sostitutiva) of 26 % on gains realized in 2025, 33 % from 2026. Regulated financial instruments tracking the same underlying asset (such as exchange-traded products on Bitcoin or Ethereum) stay at 26 %. No holding period; the €2,000 threshold (2023 and 2024 only) lapsed as of 1 January 2025.
• Revaluation (closed): Market value instead of acquisition cost against a substitute tax: 18 % as of 1 January 2025 (deadline 1 December 2025), previously 14 % as of 1 January 2023.
• Exchanges: Taxable only if the crypto assets have different characteristics and functions; otherwise irrelevant, and the coin takes over the book value.
• Staking: According to the tax administration's Circolare n. 30/E (27 October 2023), investment income (compensation for locking up the coins); Italian platforms withhold 26 % when making a distribution (Quadro RL Sezione I-A). Losses can't be offset between investment income and other income (disposal gains). The same circular, however, elsewhere also lists staking under other income; the classification is not unambiguous.
• Lending, airdrops, hard forks: No express rule; case-by-case assessment, where it should matter whether the receipt is based on mere holding or on an activity. Income from holding is taxed without any deduction.
• Proof and losses: Without reliable, precise proof, the acquisition cost is zero and the full sale proceeds are taxed. Losses can be offset against other Italian crypto gains; an excess loss can be carried forward for up to four years under the general rules for the substitute tax. The loss or theft of private keys is not a tax-relevant event, so the loss can't be claimed.
• Wealth: 0.2 % a year on crypto assets held abroad (classified as IVCA or as part of IVAFE, depending on the source); reporting on the tax form.

Year of departure

• Unlimited tax liability in Germany only ends once residence and habitual abode are actually given up. If the German home is already given up at the time of sale, the gain isn't domestic income under § 49 EStG; only with both homes in parallel does the tie-breaker decide.
• Italian residency since tax year 2024: more than 183 days (counted day by day) with at least one of three features (habitual abode, domicile, physical presence). Anagrafe registration only creates a rebuttable presumption.
• Loss positions (held for more than a year): selling in Germany brings no benefit; sold only in Italy, they can be offset.

First year after leaving

• Crypto gains are always subject to the full substitute tax; the Impatriati regime doesn't cover crypto gains and losses.
• Impatriati regime: 50 % of Italian employment or self-employment income exempt (60 % with a minor child), capped at €600,000 a year, for five years. Requirements: highly qualified work, no Italian residency in the three preceding tax years, a commitment to remain resident for at least four years (otherwise repayment with interest). The application is subject to a deadline; plan for it in the year of departure.
• Flat tax (Art. 24-bis TUIR): a fixed amount on all foreign income, for up to 15 years; €300,000 for relocation from 1 January 2026 (€200,000 from 10 August 2024, originally €100,000), €50,000 for family members (previously €25,000). Mutually exclusive with the Impatriati regime.

More than ten years

• No change for income tax purposes as things stand.
• Inheritance tax: spouses and children have a €1 million allowance per heir, 4 % above that; siblings €100,000 at 6 %; other relatives and third parties 6 % or 8 % with no meaningful allowance.
• No inheritance tax treaty: German extended unlimited inheritance tax liability applies for German nationals if the deceased or donor was fully taxable in Germany within the last five years before the inheritance; Italian tax is credited only up to the amount of the German tax. After more than ten years, the window is closed.

Moving on to a third country

• According to available sources, no special exit taxation for privately held crypto assets.
• Under the Impatriati regime, leaving before the four years expire risks retroactive clawback of the benefits, plus interest; check the minimum commitment periods.

Returning to Germany

• Returning before the four-year commitment period of the Impatriati regime expires: the same retroactive clawback, plus interest, is a risk.
• Unlimited tax liability in Germany returns; the original acquisition date still counts. If a position has been held for longer than a year in total, a sale is tax-free under § 23 EStG.