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V2432-25 11 December 2025 · SG de Impuestos Patrimoniales, Tasas y Precios Públicos Criterion in force
IP · tokens

Tokens must be declared in Wealth Tax despite sale restrictions

The consultant asks whether tokens obtained via a smart contract with a lock-up clause should be declared. The DGT responds that they must be included in net wealth due to their economic content, regardless of sale restrictions.

The question raised

Question posed: Declaration of "tokens" for Wealth Tax purposes.

The DGT's ruling

Crypto-assets or tokens that constitute assets or rights with economic content of which the taxpayer is the owner form part of their net wealth. They must be included in the Wealth Tax return regardless of whether a contractual clause exists that prevents their disposal. Their valuation must be carried out at their market price on the tax accrual date.

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