2.Investment vs Trading
Before the introduction of Article 20E, crypto gains often fell into a grey area, where the key question was whether your activities constituted "trading" or long-term investment. The 2026 reform largely removed that distinction for disposal gains.
Gains from disposals are captured by the flat 8% rule — regardless of whether the activity is classified as investment or trading. Frequency, holding period and commercial intent no longer determine the tax rate on disposal gains.
Other crypto-related income — mining rewards, staking rewards and DeFi yields — remains subject to the ordinary personal income tax rules, which are progressive (up to ~35%).
For example:
Selling crypto after a long-term hold → taxable disposal under the 8% flat regime.
Selling crypto after high-frequency active trading → also a taxable disposal under the 8% flat regime. The investment vs trading distinction no longer changes the rate.
Earning crypto from staking or DeFi yields → taxed as ordinary income on receipt at general IT rates (up to ~35%), regardless of whether the activity is passive or business-related. If those received tokens are later disposed of, that subsequent disposal is taxed at 8%.
Earning crypto from mining → explicitly excluded from the 8% regime by statute under Article 20E. Mining rewards are always taxed at general IT rates — this is not a fact-and-circumstances test but a fixed statutory rule.