Many Belgian crypto investors are aware of the tax discussions surrounding the taxation of crypto capital gains and, more specifically, the question of which tax regime applies to them. What is less well known is that merely holding certain crypto accounts may give rise to separate reporting obligations.
In practice, we find that these obligations are often overlooked. However, an unreported foreign crypto account may prompt questions from the tax authorities and may even result in administrative penalties.
In this article, we explain the two reporting obligations for holders of foreign crypto accounts: on the one hand, reporting the account as a foreign account in the personal income tax return and, on the other hand, registering it with the Central Point of Contact (CPC).
Which crypto accounts must be reported?
A common misconception is that every wallet or crypto account must automatically be reported. This is not correct.
A distinction must be made between so-called custodial wallets and non-custodial wallets. With a custodial wallet, the crypto assets are held in custody by a third party, usually a crypto exchange. The user has an account with that institution, while the platform is responsible for safeguarding the assets and providing the technical infrastructure.
With a non-custodial wallet, on the other hand, the user manages their own private keys and there is no intermediary holding the assets in custody. A hardware wallet is the best-known example.
The two reporting obligations apply exclusively to custodial wallets.
What is a foreign crypto account?
When a foreign crypto exchange acts as an intermediary and provides services comparable to those of a banking, credit, exchange or savings institution, the account is in principle considered a foreign account.
In that case, the existence of the account must be reported in the personal income tax return.
For Belgian crypto investors, in practice this often concerns accounts held with international trading platforms such as Coinbase, Kraken, Binance or similar exchanges. In concrete terms, this means that the vast majority of crypto accounts must be reported, as there are only a limited number of Belgian exchange platforms.
Reporting in the personal income tax return
Taxpayers who hold a foreign account must report it in their annual personal income tax return. This obligation therefore also applies to crypto investors when their account qualifies as a foreign account.
It is important to emphasise that this obligation is separate from the tax treatment of the crypto transactions themselves. Even if no taxable capital gains have been realised, the reporting obligation still applies.
Registration with the CPC
Reporting the account in the personal income tax return is only one part of the obligation.
When a crypto account must be reported because it is held abroad, it must in principle also be registered with the Central Point of Contact (CPC) of the National Bank of Belgium.
The CPC is a database containing information on foreign accounts held by Belgian taxpayers.
Registration with the CPC is separate from the tax return and is intended to enable the tax authorities to identify foreign account relationships.
Why is this obligation becoming increasingly important?
Tax transparency in the crypto sector is increasing rapidly.
In the future, crypto-asset service providers will be required to report increasing amounts of information to the competent authorities. In addition, from 2027 onwards, information will also
