Deciphr Academy
Track 6 · Module 30 · Lesson 6 of 7 · 6 min read

Is crypto taxed the same way in every country?

Short answer

No. As of October 2026, Australia's tax office says individuals may be able to reduce a capital gain with a discount on crypto held for at least 12 months, and Canada's tax agency shows half of a capital gain being taxed, while the US draws its line at one year and the UK uses pooling.1,2,3,4 Airdrops, losses and trading are treated differently too, so always check your own country's tax authority.5,6,2

USmore than one year: long-termUKa pool, same-day and 30-day rulesAustraliaCGT discount may apply after 12 monthsCanadahalf a gain taxed, in a CRA exampleDisposals give gains or losses; rewards are incomeSame broad idea, different details
Fig. 6. Four tax authorities agree on the broad idea, and differ on the details.
General education, not tax advice

Each country below is described from its own tax authority's pages, as dated in the sources. These rules change, and they depend on where you live and your own facts. Ask a qualified tax adviser in your country.1,2

The same broad idea

The four tax authorities in this module describe disposals in much the same way. The Australian Taxation Office (ATO) says a disposal happens when you sell crypto, gift it, swap it for another crypto, convert it to money, or buy goods or services with it.7 The Canada Revenue Agency (CRA) gives a similar list: trading it for money or another crypto, buying goods or services, and gifts or donations.2

They also agree on moving coins between your own wallets. The CRA says a transfer between wallets you own is not a taxable disposition, like the IRS and HMRC.2,8,9

Australia (ATO)

  • A capital gains tax asset. The ATO says crypto held as an investment is a capital gains tax (CGT) asset.1
  • A 12-month discount. You may be able to reduce a capital gain with the CGT discount if you held the crypto for at least 12 months.1
  • Losses. You can't deduct a net capital loss from your other income.1 In the US, by contrast, up to $3,000 a year of net capital loss can be deducted.3
  • Staking. Staking rewards are ordinary income at the time you receive them.5
  • Airdrops. If you are not running a crypto trading business and did not get the airdrop for goods or services, its value is not included in your income. Its cost base is its market value when received.5 This is not the same as the US rule for airdrops after a hard fork.10
  • Data matching. The ATO matches what people report with data on crypto transactions and accounts from service providers.7

Canada (CRA)

  • Business or capital? The CRA says a disposal can give business income or a capital gain, and which one depends on the facts, case by case. Signs of a business include frequent trading, short holding periods and borrowing to buy.2
  • Half of a capital gain. In an example on its website, the CRA shows a $5,600 capital gain "taxed at 50%", giving a $2,800 taxable capital gain.2
  • Staking. Staking rewards from a centralised exchange are generally income at the time they are credited to your wallet on the platform.11
  • Mining. In most cases, the CRA treats mining as a business, because of its scale and resources.11
US (IRS) UK (HMRC) Australia (ATO) Canada (CRA)
How long you held it More than one year makes a gain long-term3 Pooling, with same-day and 30-day rules4 Discount possible after at least 12 months1 Business or capital, depending on the facts2
Staking rewards Income when you gain control12 Miscellaneous income when received, if not a trade13 Ordinary income when received5 Generally income when credited, on an exchange11
Swapping one crypto for another A capital gain or loss8 A disposal9 A CGT event7 A disposition2

Why you must check your own country

Rules change. The IRS now keeps separate crypto answers for transactions before and after 1 January 2025.14 HMRC added a cryptoasset section to the Self Assessment return from the 2024 to 2025 tax year.15

More change may come. On 14 September 2026, a bill called the Digital Asset Tax Certainty Act (H.R. 10357) was introduced in the US House of Representatives. Its official title says it would amend the US tax code to reform the tax treatment of digital assets. Two days later, the House Ways and Means Committee voted 38 to 5 to report an amended version to the House. As of 24 October 2026, that vote was its latest step: it is not law, and this module describes the rules in force.16

Tax authorities also see more data each year. On the OECD's list of 14 September 2026, 46 jurisdictions were due to start sharing crypto data under the CARF by 2027, 27 by 2028 and 4 by 2029 (77 in all, by our count), including the UK, Australia, Canada and the US.17 But the CARF is a framework for reporting and exchanging information, not a tax rulebook.18 The tax itself still comes from each country's own rules, as the different pages in this lesson show.1,2

Our viewThe idea is the same almost everywhere: disposals give gains or losses, and rewards are income. The details are not, so always read your own tax authority's pages.
Sources
  1. How to work out and report CGT on crypto. Australian Taxation Office (ATO) (read via the Internet Archive copy of 12 October 2026, as the live site refused automated access), last updated 22 June 2026.
  2. Reporting income from crypto-asset transactions. Canada Revenue Agency (CRA) (read via the Internet Archive copy of 9 October 2026, as the live site refused automated access), page modified 2 December 2025.
  3. Topic no. 409, Capital gains and losses. US Internal Revenue Service (IRS), page last reviewed or updated 24 September 2026; checked 24 October 2026.
  4. CRYPTO22200: Cryptoassets for individuals: Capital Gains Tax: pooling. HM Revenue & Customs (HMRC), Cryptoassets Manual, manual last updated 28 November 2025; checked 24 October 2026.
  5. Staking rewards and airdrops. Australian Taxation Office (ATO) (read via the Internet Archive copy of 8 October 2026, as the live site refused automated access), last updated 19 August 2026.
  6. CRYPTO21250: Cryptoassets for individuals: Income Tax: airdrops. HM Revenue & Customs (HMRC), Cryptoassets Manual, manual last updated 28 November 2025; checked 24 October 2026.
  7. Crypto asset transactions. Australian Taxation Office (ATO) (read via the Internet Archive copy of 11 October 2026, as the live site refused automated access), last updated 22 June 2026.
  8. Frequently asked questions on digital asset transactions (Part II): sales, swaps, payments, gifts and transfers. US Internal Revenue Service (IRS), FAQs added 15 December 2025; page last reviewed or updated 29 June 2026; checked 24 October 2026.
  9. CRYPTO22100: Cryptoassets for individuals: Capital Gains Tax: what is a disposal. HM Revenue & Customs (HMRC), Cryptoassets Manual, manual last updated 28 November 2025; checked 24 October 2026.
  10. Rev. Rul. 2019-24: hard forks and airdrops (Internal Revenue Bulletin 2019-44). US Internal Revenue Service (IRS), 28 October 2019.
  11. Reporting income from crypto-asset mining and staking activities. Canada Revenue Agency (CRA) (read via the Internet Archive copy of 9 October 2026, as the live site refused automated access), page modified 10 November 2025.
  12. Rev. Rul. 2023-14: staking rewards (Internal Revenue Bulletin 2023-33). US Internal Revenue Service (IRS), 14 August 2023.
  13. CRYPTO21200: Cryptoassets for individuals: Income Tax: staking. HM Revenue & Customs (HMRC), Cryptoassets Manual, manual last updated 28 November 2025; checked 24 October 2026.
  14. Frequently asked questions on virtual currency transactions (Part I, FAQs 1 to 46). US Internal Revenue Service (IRS), page last reviewed or updated 30 June 2026; checked 24 October 2026.
  15. Check if you need to pay tax when you sell cryptoassets. HM Revenue & Customs (GOV.UK guidance), last updated 5 October 2026; checked 24 October 2026.
  16. H.R. 10357, Digital Asset Tax Certainty Act (119th Congress): bill record, titles and actions. Library of Congress, Congress.gov (read through the official Congress.gov API, api.congress.gov, as the congress.gov website refused automated access), introduced 14 September 2026; latest action 16 September 2026; checked 24 October 2026.
  17. Jurisdictions committed to implement the Crypto-Asset Reporting Framework (CARF). OECD Global Forum on Transparency and Exchange of Information for Tax Purposes, last update 14 September 2026.
  18. Delivering Tax Transparency to Crypto-Assets: A Step-by-Step Guide to Understanding and Implementing the Crypto-Asset Reporting Framework. OECD Global Forum on Transparency and Exchange of Information for Tax Purposes, 2024 (approved 4 October 2024).
← Reporting, records and data sharingNext: The Brindlecove case: a company's tax file →

General education built from the publicly available sources listed above. Not financial, legal, tax or investment advice. Naming a company, project or regulator is not an endorsement either way. Last checked 2026-10-24. Terms and disclaimer.