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V2513-25 16 December 2025 · SG de Tributación de las Operaciones Financieras Criterion in force
IRPF · criptomonedas

Cryptocurrency exchange constitutes a swap generating capital gains or losses

The consultant asked how to tax the exchange of one cryptocurrency for another due to a project restructuring. The DGT responds that this operation is a swap and must be taxed as a capital gain or loss in personal income tax.

The question raised

Taxation of the operation carried out under Personal Income Tax (IRPF).

The DGT's ruling

The exchange of virtual currencies for others, outside of an economic activity, is a barter that generates capital gains or losses. Quantification is carried out by the difference between the acquisition value of the asset transferred and the higher of the market value of the asset delivered or the asset received. The result is included in the savings tax base as savings income. The acquisition value of the new cryptocurrencies shall be the transfer value used in the barter.

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