Cryptocurrencies and Corporate Income Tax (2025): practical guide for companies in Spain

Cryptocurrencies and Corporate Income Tax (2025): practical guide for companies in Spain

In Spain there is no “crypto CIT”. Resident companies include crypto results in their accounting and are taxed under the general CIT rules.

The general rate is 25% and newly created entities apply 15% in the first financial year with a positive tax base and the following one (with exceptions).

Tax rate and tax base

The results derived from crypto purchases/sales/exchanges are added to the rest of the company’s income and expenses. For tax purposes it starts from the accounting result (PGC/IFRS) adjusted for permanent/temporary differences under the LIS. General rate 25%; 15% for new entities (first year with a positive base and the following one).

Accounting: how to classify cryptocurrencies

• Inventory (IAS 2) if they form part of the business purpose (e.g., habitual “trading”/market making).

• Intangible (IAS 38) if they are held as a treasury investment or other purposes.

This is the interpretative criterion established by the IFRS IC and reflected by the ICAC.Practical consequence: if measured at cost there is no tax until sale; if fair value with impact on P&L were applied, the changes would affect the accounting profit for the period (and, therefore, the base, with the adjustments that apply).

“Trading” or proprietary investment in crypto (not for third parties)

When the company buys and sells for itself, the realised gains from sales/exchanges are included in the base of the financial year in which they are carried out. There are no “savings/general” compartments: in CIT everything enters the single corporate base. Tax loss carryforwards (negative bases) can be offset in future years with the general limits of the LIS (no special regime for being crypto).

Crypto service companies (exchange, broker, custody, mining, staking-as-a-service)

• Exchange/broker: fees are operating income. For VAT, the exchange of traditional currencies for bitcoin is exempt (CJEU Hedqvist, C-264/14); other operations require case-by-case analysis.

• Industrial mining: income for the value of the mined crypto minus expenses (electricity, depreciated hardware, etc.). For VAT, mining is usually treated as not subject as there is no identifiable recipient (administrative criterion derived from the CJEU).

• Staking/“interest”: recognised as financial income (accounting criterion); its treatment for VAT/withholdings will depend on the specific taxable event and the chain of consideration.

Collections and payments in crypto

If you accept crypto as a means of payment for your product/service:

1. Sale: you accrue VAT (if applicable) and recognise income in euros at the market value of the crypto at that moment.

2. Asset received: you recognise the cryptocurrency on the balance sheet at that value.

3. Subsequent sale/exchange of that crypto: it will generate a gain/loss that impacts P&L and CIT. If you pay suppliers/employees in crypto, it is payment in kind: apply the labour/tax rules and, where appropriate, withholdings.

Informative obligations (only if you provide crypto services)

Entities resident in Spain that custody crypto for third parties or intermediate/execute operations must file:

• Form 172 (balances in virtual currencies).

• Form 173 (operations with virtual currencies).

Both were approved by Order HFP/887/2023 (BOE 29/07/2023). The AEAT maintains FAQs and technical notes, and has updated requirements (e.g., more decimals in 172 for 2025). If you are not a custodian/intermediary, it does not apply to you.

Quick example (sale + collection in crypto)

• Fact: you sell a service for €10,000 on 15/03/2025 and collect 0.20 BTC (BTC at €50,000).

• Accounting/VAT: income (€10,000) and, if applicable, VAT charged on €10,000; you recognise 0.20 BTC on the balance sheet for €10,000.

• Afterwards: if on 30/06/2025 you sell those 0.20 BTC for €12,000, you record +€2,000 result (before expenses), which is included in the CIT base.

Operational checklist for your company

• Accounting policy: classification (inventory vs intangible) and measurement (cost vs FV through P&L).

• Pricing procedure: source of fair value (markets, oracles, daily close).

• Traceability: documentation of transactions (txid, exchange, counterparties, supporting documents).

• Taxation: control of tax loss carryforwards and accrual criteria.

• If you provide crypto services in Spain: verify the 172/173 obligation and deadlines.

There are no tax advantages “for being crypto”. The key is a good accounting fit, transaction trace, and applying the general rules of the CIT and, if you are a CASP in Spain, complying with 172/173.

Quick notice: This post summarises general criteria in force as of 02/10/2025. Confirm your specific case (activity, volume, role with third parties) and supporting documentation. Main legal basis: LIS (Law 27/2014) and ICAC/IFRS criteria; AEAT informative obligations (172/173).