The situation
A description of the group’s crypto holdings, staking and payments, by entity
Your software company in Vienna holds part of its treasury in bitcoin, has subsidiaries in Munich and Wrocław, and since spring has accepted USDC from some customers. The German subsidiary has started staking a small ether position. The auditors want a note on how each activity is taxed and accounted for in each entity before they sign the year-end accounts.
The activities are simple. The hours go on the fact that crypto-assets sit awkwardly in rules written for currency, securities and goods. Each country answers on its own terms how a company’s gains are taxed, when staking income arises, how holdings are valued and what VAT applies when customers pay in tokens.
What the research has to settle
The rules behind the answer
- Company gains are business income
- Holding-period exemptions that some countries give private individuals, such as Germany’s one-year rule for private sales, do not apply to a company. A corporation’s gains on crypto-assets are taxed within its profits, under rules the research confirms per country.
- Exchanging bitcoin for currency is VAT-exempt
- In Hedqvist (C-264/14) the Court of Justice held that exchanging bitcoin for traditional currency is an exempt transaction concerning currency. Selling goods or services for crypto does not change the VAT on the sale itself.
- Staking income needs its own analysis
- When staking rewards become taxable, and at what value, is not settled the same way everywhere. The note should state each country’s position with its source, or say plainly that it is open.
- Accounting shapes the tax base
- Under IFRS, the IFRS Interpretations Committee concluded in 2019 that crypto-currencies held are generally intangible assets, or inventory if held for sale in the ordinary course of business. National accounting rules may differ, and the valuation can flow into the tax base where national law links them.
How it runs in azta
From the question to the document
The question, as you would type it
Austrian parent holds bitcoin as treasury; German GmbH stakes ether; Polish sp. z o.o. accepts USDC from customers. How is each taxed for corporate income tax, when does staking income arise, and what is the VAT position on payments received in USDC?
You start with
A description of the group’s crypto holdings, staking and payments, by entity
- 01
Describe each activity and entity
Set out holdings, payments and staking by entity. azta searches the German, Austrian and Polish tax legislation and EU VAT law.
Cited research· Free - 02
Check the court decisions
Ask for the Court of Justice decision on bitcoin and VAT and the German and Polish decisions on crypto income. azta links each to the full text.
Case-law search - 03
Draft the note per entity
Ask for a note with one section per entity and activity, the source for each position and the open points. Edit it in Canvas.
Canvas · Ask azta· Pro - 04
Export for the auditors
Export to Word and keep the cited research with the year-end file.
Word export· Pro You send
A tax treatment note per entity and activity, with open positions marked
What you get
A tax treatment note per entity and activity, with open positions marked
Tax note · draft
Crypto-assets in the group: tax treatment by entity
Austrian parent, bitcoin treasury. Gains and losses on disposal form part of the company’s taxable profit, and no holding-period exemption applies to a company. The year-end valuation follows the accounting policy in section 2, and the tax effect is set out with the provisions cited.
German subsidiary, ether staking. Whether rewards are taxed when received or on disposal, and at what value, is addressed with the sources in section 3. The position chosen should match the accounting treatment and be applied consistently.
Polish subsidiary, USDC receipts. The VAT on the software sold is unchanged by the means of payment. Whether converting the USDC into złoty is exempt in line with Hedqvist, which concerned bitcoin, and how the conversion is treated for corporate income tax, are set out in section 4.
Outcomes on your numbers
What azta is worth on this task
Pro pays for itself after
18 minutes a month
At €95 an hour, that is all the time Pro (€27 a month) has to take off your desk to cover its price.
Example figures. Replace them with your own.
- Hours back a year
- 22
- Capacity at your rate
- €2,052
- More crypto tax notes a quarter
- 0.7
- Return on Pro
- 6.3×
- Research
- Drafting
- Your review
A scenario you set, not a promise. The hours that come back go to another client, or deeper into this one.
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Book a demoSources azta searches here
- EUR-Lex · Curia
- Gesetze im Internet
- Rechtsprechung im Internet
- RIS
- Dziennik Ustaw
What stays with you
- The transaction records and valuations, from your wallets and exchanges.
- The accounting policy, agreed with the auditors.
- Positions where the law is open, which you take and document.
Frequently asked questions
- Does azta hold tax authority guidance on crypto?
- Not for every country. It holds legislation and case law, and the guidance of only some authorities. It cites what it relies on, so you can see where a ministry letter or ruling still needs checking.
- Does it cover the new EU reporting rules for crypto?
- It holds EU law, including the directive that extends tax reporting to crypto-asset service providers. Ask about it as a separate question.
- Can it value our holdings?
- No. Valuation uses your records and prices. azta explains the rules that govern the valuation.
