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The DGT clarifies that staking revenue is classified as capital gains or patrimonial gains depending on the nature of the operation and asset availability.
Question raised 1. Taxation under Personal Income Tax of the income obtained by the taxpayer in the various modalities of "staking".
In centralized staking, income constitutes full returns on movable capital obtained through the in-kind transfer of own capital. In native staking, these are also in-kind returns on movable capital, taxable when rewards are credited to a wallet from which they can be accessed. In liquid staking, the exchange of crypto-assets (such as ETH for rETH) constitutes a barter that generates capital gains or losses.
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