The 2026 expansion needs a fresh crypto analysis
Article 6 of Title 7 now covers specified foreign capital returns and related gains, alongside domestic-source income. Ordinary remaining capital income falls under the 12% rate in Article 37. DGI consultation 6419 classifies cryptocurrency as an intangible movable asset when exchanged for property; it does not settle the location or 2026 treatment of every token. Whether a disposal falls within the foreign-capital provisions, an exception or another category needs a current opinion. A universal 0% crypto entry is therefore not supported here.
Arrival-year plus ten following years
For people becoming tax resident from 1 January 2026, DGI describes an irrevocable election for covered foreign capital income and gains. The person must not have been resident in the two preceding fiscal years or previously used the old holiday. The route requires more than 183 days of effective presence each year, or another residence basis combined with qualifying real estate above 12.5 million UI or annual qualifying fund capitalisation of at least 625,000 UI. Annual proof and the election are required. It is not enough to obtain an immigration permit.
The years after the holiday
Article 24 bis provides a further five-year option at half the applicable IRPF rate with specified additional investment, or an annual fixed-charge option within a period extending to twenty fiscal years after the first election. The standard fixed amount is 1.875 million UI; qualifying effective-presence or business-investment cases can use 1.25 million UI. Covered spouses pay 15% of the relevant fixed amount. These are indexed-unit charges, not fixed US-dollar prices. Establish that the crypto receipt is within the covered foreign-capital category before comparing the cost.
Keep the taxable base separate from the percentage
For covered foreign asset disposals, the current regulation provides an annual option to calculate taxable income as 20% of sale proceeds. At a 12% applicable rate, that would equal 2.4% of gross proceeds, not 2.4% of the gain. This calculation is conditional on the transaction falling within that provision; it is not a verified universal crypto turnover tax. A loss, reward receipt or locally operated business needs its own analysis, including any applicable wealth-tax and reporting questions.