Italy introduced a dedicated crypto-asset tax regime in 2023 that is broadly modelled on its longstanding financial income tax system. The regime primarily governs the taxation of capital gains and other income from crypto-assets for individuals, thereby offering initial legal certainty for users and service providers. However, it establishes a single set of rules for all crypto-assets regardless of their functions or underlying rights and leaves several stages of the crypto-asset lifecycle and many asset-specific tax issues insufficiently addressed. This article analyses the regime’s core design features through the lenses of efficiency and equity and assesses the framework’s ‘future-proof’ capacity in light of rapid technological change with specific attention focused on decentralized finance (DeFi), asset-tokenization, stablecoins, and central bank digital currencies (CBDCs). Finally, it examines enforcement challenges and shows how reliance on the traditional ‘third party tax agent’ model struggles to accommodate the anonymity (or pseudo-anonymity), decentralization, transaction-composability, and a-territoriality of crypto-assets. Against this background, the article identifies potential policy adjustments and alternative compliance mechanisms to enhance the effectiveness and resilience of the Italian framework.
Alessandra Sanelli (Thu,) studied this question.