Losses, the 2025 step-up, intermediaries and the tax return

Paolo closed 2025 with €4,000 of losses on a token that collapsed, and in 2026 he makes €10,000 selling bitcoin. If he reported the loss in his 2025 return, he pays 33% on €6,000, which is €1,980. If he forgot, he pays €3,300. The €1,320 difference comes down to one line of section RT, filled in or left blank.

Offsetting losses

Article 68(9-bis) of the TUIR says that gains under letter (c-sexies) are added algebraically to the matching losses. If losses exceed gains in a year, the surplus is carried forward in full against gains of the following years, but no later than the fourth.

The condition is the same as for other financial assets: the loss has to appear in the return filed for the year it arose. A loss that was never reported cannot be recovered later, however well documented it is and however large it was.

The words in full carry particular weight across the 2025-2026 boundary. A loss from 2025, when the rate was 26%, reduces a 2026 gain taxed at 33% by its whole amount. None of the provisions read for this course scales it down.

Each year, then, the remaining loss has to be carried into the new return and updated. Someone who stops filing, or forgets to pick up last year's balance, risks giving up a right the law grants.

Paragraph 9-bis talks about gains of later years. Holding proceeds, which the same provision taxes without any deduction, are not the natural place to absorb a loss: check the instructions for that year's return before relying on it.

A basket kept apart from shares

For shares, bonds, funds and derivatives, offsetting is governed by paragraph 5 of the same Article 68, which groups letters (c) to (c-quinquies). That paragraph does not mention letter (c-sexies). Paragraph 9-bis, for its part, only speaks of losses on crypto-assets.

The text therefore builds no bridge between the two baskets. A loss on selling shares does not reduce a gain on a cryptocurrency, and the reverse is also true. Anyone investing in both worlds needs two separate loss ledgers, each with its own four-year horizon.

The step-up of value at 1 January 2025

In paragraph 26 of Article 1, Law 207/2024 offered an option to anyone holding crypto-assets on 1 January 2025. For each one, the value at that date could replace the historical cost, provided that value was subjected to an 18 per cent substitute tax.

The tax was due by 30 November 2025, or in up to three equal annual instalments from that date, with 3 per cent annual interest on the instalments after the first. Paragraph 29 adds an important limit: the stepped-up value cannot generate usable losses.

The downside shows when prices fall. Had Laura sold at 18,000 euros, below the stepped-up value, the 2,000 euro shortfall against that value could not have been used. She would have paid 3,600 euros for a higher cost base that, in that scenario, does her no good.

In essence, the option was a bet on future prices. It suited holders sitting on a large unrealised gain who expected to sell higher: they paid 18% on the full value to avoid 33% later on the part of the gain accrued before 2025.

It made little sense, on the other hand, for someone whose historical cost was close to market value: the 18% hit the entire value, not just the gain, and the future saving would have been small or nil.

The window to opt in closed in 2025. Those who used it must keep proof of payment and of the valuation, because the new cost only counts if the substitute tax was actually paid. Anyone who paid in instalments should also check that every later instalment, with its interest, was settled on time.

Intermediaries: administered and managed regimes for crypto too

Article 6 of Legislative Decree 461/1997, the administered savings regime, now also covers redemptions, sales, swaps and holding of crypto-assets. If the taxpayer elects for it, the intermediary applies the tax to each transaction and pays it on the client's behalf.

For crypto-assets the election can be made not only with banks and investment firms but also with the non-financial operators listed in letters (i) and (i-bis) of Article 3(5) of Legislative Decree 231/2007, the anti-money-laundering law.

Two rules in paragraphs 3 and 4 of that article matter in practice. For crypto-assets the self-certification that lets clients declare their own cost for other instruments is not allowed: documents are required. And the intermediary uses the weighted average cost of each homogeneous category.

The transfer rules apply to crypto-assets as well. Moving them to an account in other people's names is treated as a sale for consideration, unless it results from inheritance or gift, and the intermediary works out the gain using what the assets are worth on the day they move.

Article 7, on individual portfolio management, also includes crypto-assets. Where they exceed 10 per cent of average managed assets, paragraph 5 requires them to be valued at normal value, and the taxpayer may revoke the election for those assets alone.

As with securities, losses on crypto-assets under the administered regime stay in the account where they arose. When the account is closed or the election revoked, the intermediary issues a certificate that lets them be used in another account held by the same persons, or in the return, within the fourth year.

Doing it yourself or using an intermediary

Many crypto investors trade on foreign platforms that do not act as Italian withholding agents. For them the regime is in practice the self-reported one: their own calculation, section RT, payment with the income tax balance. Nobody else will do the arithmetic or remind them of the deadlines.

Someone with a few trades a year can handle self-reporting with a tidy log. Frequent traders, especially those swapping between different tokens, may find real relief in the administered regime, provided they hold the purchase documents the intermediary will ask for.

Under self-reporting the tax is paid months after the gain, with the following year's balance. Under the administered regime it is paid at once, withheld from the proceeds. The choice does not change the rate, but it changes the workload, the payment timing and how losses meet gains.

Section RT and section RW

Anyone not using an intermediary under the administered regime reports gains and losses personally in section RT of the Redditi Persone fisiche return. For 2025 income, part V-A takes crypto gains realised by 31 December 2025, which bear the 26 per cent tax.

For 2026 income, taxed at 33%, you will need the return the Revenue Agency publishes in 2027 and should check its instructions for the right part. Losses brought forward from 2025 must be picked up from the previous year's return.

Section RW serves another purpose. It is used for tax monitoring, and resident individuals must complete it for crypto-assets held through wallets, digital accounts or other storage or custody systems. It tells the tax authorities what you own, whether or not you sold anything.

The same section RW is where the tax on the value of crypto-assets is settled, under Article 19(18) of Decree-Law 201/2011 as amended by the 2023 Budget Law. As its name says, it falls on the value of the crypto-assets held rather than on gains, so it also concerns people who sold nothing during the year.

This course does not give its rate, because the Revenue Agency page read for it refers to the return's PDF instructions. Holders of crypto-assets should check it there, together with the rules for measuring value.

What to prepare before filing

A crypto holder's return is prepared during the year, not in May. The work shrinks a great deal if each transaction is logged when it happens and if, at year end, the full history is downloaded from every platform and every wallet.

• The transaction history of every platform, with dates, quantities and euro values
• Proof of purchase cost: order confirmations, statements, bank transfers to the platform
• A schedule of earlier-year losses still usable, showing the year each arose
• Certificates issued by intermediaries under the administered regime, including closing ones
• For those who stepped up, the valuation at 1 January 2025 and the payment receipts
• A list of wallets and digital accounts held, with the values needed for section RW

With these documents section RT becomes an addition and section RW a list. Without them the risk is not just a mistake: it is paying tax on a zero cost or losing losses that could have been used.

Heavy traders may turn to an adviser or tax software, but responsibility for the data stays with the taxpayer. No tool can rebuild a cost that was not documented when the purchase was made.