Spain: crypto taxes when leaving Germany

• Disposal and exchange: No time component. Savings-base schedule (“base del ahorro”) of 19 % to 30 %: first roughly €6,000 at 19 %, 30 % since 1 January 2025 above €300,000. Crypto-to-crypto exchange is taxable.
• Mining and airdrops: generally in the general tax base (base general), progressive up to 47 %. Mining can be an economic activity if organized independently and carried out systematically (registration and declaration duties generally apply; IAE registration for services to third parties).
• Staking, liquidity mining, hard forks: The Spanish tax administration generally treats classic staking income as investment income (19 % to 30 %); for lack of any dedicated statutory or published administrative rule, liquidity mining is generally assigned the same classification as staking and lending in advisory practice, and thus generally treated as investment income. Hard forks: no express rule; treatment and acquisition value not conclusively settled.
• Method and losses: FIFO mandatory; losses can be offset within the savings base and carried forward four years.
• Filing: Modelo 100 between April and June of the following year. Crypto assets held abroad worth more than €50,000 generally have to be reported via Modelo 721 (purely declaratory; 1 January to 31 March; in later years only if the balance has risen by more than €20,000).
• Wealth and inheritance: Wealth tax (roughly 0.2 % to 3.5 %) and inheritance and gift tax are regional (17 autonomous communities); inheritance reductions for close relatives range from near-complete exemption to noticeable burdens.

Year of departure

• German unlimited tax liability ends only when residence and habitual abode are actually given up. Spanish tax residency: more than 183 days in the calendar year or the center of economic interests there; presumed if a spouse (not legally separated) or minor children live there, unless proven otherwise.
• German home already given up at the time of a sale: no domestic income under § 49 EStG, regardless of the tie-breaker.
• Loss positions held longer than a year should not be sold before emigrating: in Germany, such a loss isn't captured; in Spain, it can be offset against other Spanish capital gains of the same year, with an excess loss carried forward up to four years. If the Beckham regime is planned, coordinate disposal timing individually.

First year after leaving

• Self-custody (Modelo 721): under the AEAT's view so far, a position counts as “held abroad” if no Spanish provider is interposed, wherever the private key is; some advisors take the opposing position; a highest-court ruling is pending, so a cautious approach is advisable.
• Beckham regime (Art. 93 LIRPF): relocated employees, online workers for a foreign company, managing directors of their own companies, ENISA-certified freelancers; not tax resident in Spain in the last five years; application mandatory within six months of starting the activity or registering with social security.
• Effect: up to six tax years at a flat 24 % on employment income up to €600,000 (47 % above); Spanish investment income stays at 19 % to 30 %; foreign income other than employment income, capital gains included, stays exempt under the rule's wording. Crypto gains qualifying as foreign income generally aren't subject to Spanish income tax (prevailing view: particularly for crypto assets held abroad); an express highest-court confirmation is pending, and the reasoning relies on the general rules on foreign income under the regime, not on a crypto-specific confirmation from the Spanish tax administration.
• Wealth tax under the Beckham regime counts only assets in Spain; crypto held abroad generally stays out unless the national solidarity tax applies. Beckham users are exempt from Modelos 720 and 721. Without a recognized reason for relocating, the regime generally can't be used; it's generally not accessible to purely passive crypto investors.

More than ten years

• Wealth tax: nationwide allowance of €700,000 unless a region sets another; Madrid grants a 100 % rebate; the national solidarity tax from around €3 million partially undoes regional rebates.
• No inheritance tax treaty: German extended unlimited inheritance tax liability applies to German nationals if the deceased or donor was fully taxable in Germany within the last five years before the inheritance; after more than ten years, the window is closed.

Moving on to a third country

• Exit tax (Art. 95 bis LIRPF, Law 26/2014, from 1 January 2015): resident for at least ten of the last fifteen tax years; shares worth more than €4 million, or more than €1 million with a shareholding above 25 %. By its wording it covers shares and other company holdings, not privately held crypto assets; application to them currently seems far-fetched; no highest-court ruling.
• Move to an EU or EEA state: under the statutory conditions, deferral of up to ten years; generally triggered by a sale of the shareholdings, a move of residence to a third country, or a breach of certain notification obligations.

Returning to Germany

• Unlimited tax liability returns. The original acquisition date counts: if held longer than a year in total, a sale is tax-free under § 23 EStG insofar as the holding stayed unchanged; after a sale and reacquisition before emigrating, the new date applies.