The growth of investment in crypto-assets has highlighted an often-underestimated truth: technology is global, but taxation remains profoundly local.

While Bitcoin, tokens, and digital assets can be traded anywhere, the moment capital gains are realized, they are inevitably tied to a specific tax jurisdiction.

Consequently, many digital investors are looking beyond national borders in search of countries that offer not only tax efficiency but also clear regulations, operational banking, and regulatory stability.. Among the most prominent jurisdictions are Italy, Portugal, Switzerland, and Malta, each possessing distinct characteristics.

Italy: A Defined but Inflexible System

In Italy, the taxation of crypto-assets has reached a level of regulatory definition, yet it is becoming significantly more burdensome. Capital gains realized from January 1, 2026, are subject to a substitute tax increased to 33% for most cryptocurrencies (such as Bitcoin, Ethereum, and USD-pegged stablecoins). Exceptions are made for Euro-anchored E-Money Tokens (if MiCA-compliant), which maintain a 26% rate. 26%. Furthermore, current legislation (in effect since 2025) has removed the exemption threshold for small gains, making every capital gain tax-relevant, regardless of the amount.

This regulatory clarity comes at a price. The Italian system is not only the most expensive among the jurisdictions analyzed (33% vs. exemption in Switzerland or corporate optimization in Malta), but it also struggles to adapt to more complex crypto models. Additionally, the relationship with the banking system remains frequently problematic.

The result is a non-competitive environment for entrepreneurs and sophisticated investors.

Portugal: Attractive Only on the Surface

Portugal was long considered a premier destination for crypto investors due to its extremely favorable tax treatment. In recent years, however, the framework has changed significantly.

New rules introduce distinctions based on holding periods and the nature of the activity: capital gains derived from crypto-assets held for less than 365 days are now taxed at a flat rate of 28% for individual investors. Conversely, an exemption is maintained for holdings exceeding one year. Added to this is a structural element often overlooked: the absence of a truly regulated crypto ecosystem.

Portugal may still work in specific cases (individual investors with a long-term horizon), but it offers little guarantee in terms of operational continuity, banking access, and interpretative certainty for traders and high-frequency operators.

Switzerland: Solidity and Reputation, but Not for Everyone

La Svizzera rappresenta uno dei contesti più maturi in Europa per gli asset digitali.

Switzerland represents one of the most mature environments in Europe for digital assets. The authorities’ approach is pragmatic, dialogue with the industry is advanced, and the level of legal certainty is among the highest internationally.

From a tax perspective, capital gains generated by private investors (i.e., non-professionals) are generally tax-free (0% capital gains tax). However, this status is assessed on a case-by-case basis, based on concrete factors such as volume, transaction frequency, and the organization of the activity.

If the activity is classified as professional, capital gains are taxed as business income, with progressive rates that can be significant.

Switzerland remains an excellent choice for structured and capitalized operators, but it entails high costs and stringent requirements, making it less accessible for crypto startups or medium-sized investors.

Malta: Crypto Regulation and Legal Certainty

Malta has adopted a profoundly different approach compared to many other European jurisdictions. Instead of chasing the crypto phenomenon, it chose to regulate it organically, creating a dedicated regulatory framework for digital assets. This means the investor does not operate in a “grey area” but within rules specifically designed for the crypto sector.

Maltese taxation is not based on promises of generalized exemptions for individual investors, but rather on structured planning, especially when operations are conducted through companies or appropriate investment vehicles. By utilizing the tax refund system (full imputation system), it is possible to achieve an effective corporate tax rate between 0% and 5% on profits. A key element is the operational context.

Malta offers:

• A regulated crypto ecosystem;
• Banks and payment providers accustomed to working with crypto operators;
  
• A consistent approach between tax regulations and financial regulations.
  

These factors make Malta a predictable, defensible, and truly viable jurisdiction for managing crypto-asset capital gains through corporate structures.

Informed Planning for Crypto Capital Gains

The question “where is it most advantageous to realize capital gains?” has no single, universal answer. The choice of jurisdiction must take several elements into account, including:

• The investor’s profile (private or professional);
• The volume and frequency of operations;
• The necessity of operating through corporate structures;
• The relationship with the banking system.

In this context, Malta emerges as one of the most balanced European solutions, as it allows for the combination of tax efficiency, clear regulation, and legal certainty without sacrificing operational capability.

This is precisely where Cartesio provides value: supporting digital investors, crypto entrepreneurs, and international structures in choosing the most consistent jurisdiction, building appropriate vehicles, and managing the taxation of capital gains in a sustainable and defensible manner over time.