Sec. 15 EStG Service · Legal position 08/2026

Mining and node operation

Between a node that makes your own transactions traceable and a mining rig in the cellar lie worlds, for tax purposes. The first task is therefore to classify the facts correctly — the arithmetic comes afterwards.

The essentials
  • A node serving solely to follow your own transactions creates no trade — there is neither income nor participation in general commerce.
  • Mining on purpose-bought hardware with a permanent setup, by contrast, is generally a trade.
  • Block rewards are valued at the market price when they accrue — with frequent distributions, a great many individual valuations.
  • Hardware is depreciated; electricity costs must be apportioned and evidenced.
  • Whether taxation at the moment of accrual is systematically correct is in our view a question needing clarification.

A node run for your own use creates no trade

A worry we meet regularly — and one that can be resolved in a few sentences.

The basic conditions are simply not met

Under section 15(2) of the Income Tax Act, a trade requires an independent, sustained activity carried on with the intention of making a profit and amounting to participation in general commerce. Someone running a node purely for themselves meets none of this.

No income is generated, no service is offered on the market, and there is no participation in commerce. The node is a technical aid to managing your own assets — no different from a spreadsheet or accounting software.

The usual reasons for running one

Wanting to run your own wallet without a third-party provider, to follow your transactions independently, or to obtain data for your own tax return are all objective reasons. The last of these comes up often: a node supplies the history that a closed exchange no longer provides.

  • No tradenode used solely to follow your own transactions
  • No traderunning your own wallet without a service provider
  • No tradeobtaining data for your own tax return
  • Assess separatelynode with a share of rewards or a staking function
  • Assess separatelyrunning nodes for others for a fee

The line shifts as soon as the node produces income — as a validator sharing in rewards, for instance — or is run for others. The same criteria as for mining then apply, and the assessment starts again.

Our advice: record the purpose. A short note of when and why the node was set up costs five minutes and ends the discussion in a later audit.

When mining becomes a trade

Unlike pure trading in crypto assets, mining often does amount to a trade — because something is genuinely produced and exploited.

Points towards a trade

What speaks for it

Purpose-bought hardware, an operation set up to last, a separate electricity contract or site, planned reinvestment in further capacity, participation in a mining pool aimed at regular income, and the scale of the resources deployed.

Points towards private

What speaks against it

Use of hardware you already own, occasional activity not set up to last, no economic plan, no reinvestment, and income on a scale that does not cover the outlay.

What the classification means in practice

If mining is classified as a trade, the mined coins belong to the business assets. There is no holding period there: the later sale is fully taxable, however long the coins were held. That is regularly the larger effect, greater than trade tax itself, which for individuals is largely credited.

Conversely, within a business, hardware, electricity and premises are deductible — with a rig of any real electricity consumption, that can be substantial. The classification is therefore not merely an irritation but a calculation with two sides. The full analysis

Valuing block rewards

The most laborious part of the work — and the part where standard software fails most often.

Mined coins are recognised at their market value when they accrue. With a pool distributing daily or hourly, a year quickly produces several thousand individual valuations, each needing a time of accrual and a price.

What matters here

  • A single documented price source — and not changing it during the year.
  • The time of accrual per credit, rather than aggregation into monthly totals.
  • Separating the block reward from transaction fees, where they are shown separately.
  • Distinguishing the later sale: that is its own event, with its own result measured against the value on accrual.

If the price falls between accrual and sale, a loss arises against the value recognised; if it rises, an additional gain. Collapsing the two produces a result that is wrong both as to timing and as to amount.

We cross-check every position by machine as well: times of accrual, prices applied, totals per pool and the consistency of holdings. Every deviation is flagged and resolved by hand before any figure enters the return.

Hardware, electricity and premises

The business expenses follow the familiar rules — but the evidence decides.

Depreciation

Writing off hardware

Computers, graphics cards, ASICs and accessories are depreciable fixed assets written off over their useful life. Low-value assets may be deducted immediately. Where technical obsolescence shortens that life, the shorter period must be reasoned.

Electricity

Apportioning electricity

Where the rig runs in a private household, the business share must be established. A sub-meter is the best evidence; failing that, a traceable calculation from power draw and running time. Without an apportionment the figure will be estimated — not in your favour.

Premises

Rooms and premises

A room used specifically for the activity may be deductible; the conditions differ according to whether it is a home office within the meaning of the rules or a room used for business purposes. With a rig needing significant space and cooling, this warrants separate examination.

Cessation

Do not forget cessation

If mining stops, the remaining assets must be withdrawn or sold and the gain on cessation computed. Coins still held are regularly overlooked here, although they can be the largest item.

Records

Keeping records

Running times, hash rate, pool statements, electricity bills and purchase invoices belong in an ordered file. In an audit those documents are worth more than any explanation given afterwards.

The open question: taxed on accrual or only on sale?

A case we are preparing — and one that would matter considerably for miners.

Mining in preparation

Is there already a realised increase in wealth at the moment of accrual?

The tax authorities value mined coins at the market price when they accrue. Two objections seem to us to need clarification.

The economic one: if the price then falls, tax is payable on a value never realised. With an asset class of this volatility that is not a marginal case but the normal case in a downturn.

The systematic one: with self-mined coins the asset comes into existence only through your own activity. Whether that already constitutes a realised increase at the moment of creation, or whether taxation ought to attach to the disposal, is a question of the realisation principle — and therefore of ability to pay.

What this means for you

Anyone mining and holding the rewards should not let the assessment become final. An appeal costs no fees and keeps the question open. The appeal procedure

VAT on mining

Whether mining income is within the scope of VAT has not been conclusively resolved. The main argument against it is the absence of an identifiable recipient: the block reward is not paid by a particular principal but arises under the protocol. Without an exchange of supply and consideration in the VAT sense, there is nothing to attach to.

The position can be different for transaction fees attributable to a specific principal. It also changes where rigs are run for others or computing power is sold.

Input tax matters here too, and practically so: anyone taking the view that there are no taxable supplies cannot recover input tax on the hardware either. With a rig costing six figures that is a question to settle before the purchase, not after it.

Questions and answers

Is mining always a trade?
No, but often. What decides is the overall assessment: scale, capital and hardware employed, permanence, participation in general commerce, and the intention to make a profit. Occasional mining on hardware you already own, without any economic plan, may still be private asset management; a rig run permanently on purpose-bought hardware with its own electricity contract generally is not.
I only run a node to follow my own transactions. Is that a trade?
No. Someone running a node solely to follow their own transactions, to operate their wallet without a third-party provider, or to obtain data for their own tax return, does not participate in general commerce and derives no income from it. The basic conditions of section 15(2) of the Income Tax Act are simply not met. The node is then a technical aid to managing your own assets — no different from accounting software.
How are block rewards valued?
At the market price when they accrue, that is, when they are credited. With daily or hourly distributions that produces a great many individual valuations. Whether valuation at the moment of accrual is systematically correct is in our view a question needing clarification — we are preparing a case on it.
Can I deduct my electricity costs?
Yes, to the extent they are incurred for the business. Where mining takes place in a private household, the business share must be established and evidenced, ideally through a sub-meter. Without a traceable apportionment the deduction will be cut in an audit, and generously so.
What happens to the hardware if I stop mining?
If the business is discontinued, the remaining assets must be withdrawn or sold — including any coins still held. The gain on cessation must be computed. The coins are regularly overlooked here, although they can be the largest item.
Do I have to charge VAT on mining income?
That is disputed. The main argument against a taxable supply is the absence of an identifiable recipient and of an exchange of supply and consideration in the VAT sense. For transaction fees attributable to a specific principal, the assessment can differ. We look at this case by case.
Responsible for content: Matthias Steger, German certified tax advisor (Steuerberater), nine years as a tax auditor, author of the handbook on the taxation of crypto assets.
Legal position: 25 August 2026. Sources: sections 4(3), 6 and 15 of the Income Tax Act; the VAT Act; and the Federal Ministry of Finance circulars on the income taxation of crypto assets.
The passages on the open legal question reflect our own legal view. This page is not advice on an individual case. Where this English text and the German version differ, the German version governs.

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