As we delve into the world of cryptocurrency taxation in Europe, we find ourselves at the intersection of cutting-edge technology and complex fiscal policies. The rapid growth of the crypto market, with its soaring market capitalization and increasing adoption by investors, has prompted governments across the continent to grapple with the challenge of taxing digital assets. Our focus on five key European nations provides a comprehensive overview of the diverse approaches to cryptocurrency taxation, highlighting the intricate balance between fostering innovation and ensuring regulatory compliance.
In this article, we will explore the European Union’s stance on cryptocurrency and examine the specific tax policies implemented by Germany, France, the United Kingdom, Italy, and Spain. We’ll analyse how these countries are adapting their tax systems to accommodate the unique characteristics of blockchain-based assets like Bitcoin. Additionally, we’ll discuss the cross-border implications of crypto taxation, the challenges faced by policymakers in implementing effective tax strategies, and the potential impact on crypto exchanges and investors. By examining these aspects, we aim to provide valuable insights into the evolving landscape of cryptocurrency taxation in Europe.
European Union’s Stance on Cryptocurrency
At the European Union (EU) level, the approach towards cryptocurrency taxation has been evolving rapidly. In May 2023, the EU passed new legislation to address the risks associated with crypto-assets and ensure financial transparency. The Regulation 2023/1113 requires crypto-asset service providers to collect and make available information about the sender and beneficiary of transfers, irrespective of the transaction amount, to combat money laundering and terrorism financing. The Regulation 2023/1113 shall apply in EU from 30 December 2024. We’ll be coming back to this in a dedicated publication in the near future.
Current Directives
The EU has already taken steps to regulate the crypto-asset market. The 2020 digital finance strategy laid the groundwork for a comprehensive legislative framework that regulates the issuance of crypto-assets and related services. Crypto-assets are defined as digital representations of value or rights that can be transferred or stored electronically using distributed ledger technology (DLT). The EU recognises the potential of crypto-assets to streamline capital-raising processes, enhance competition, and create innovative financing opportunities for consumers and small and medium-sized enterprises (SMEs).
Proposed Regulations
In June 2023, in entered into force the Markets in Crypto-Assets (MiCA) Regulation (Regulation 2023/1114), which aims to protect investors, preserve financial stability, and foster innovation in the crypto-asset sector. MiCA defines crypto-assets as digital representations of values or rights, storable and transferable electronically using DLT. The regulation focuses on stablecoins, which are crypto-assets pegged to official currencies or a basket of currencies or values, as they represent a potential alternative means of payment, especially in international contexts.
The MiCA framework introduces organisational, operational, and prudential requirements for crypto-asset issuers and service providers. It aims to mitigate risks such as market manipulation, insider trading, cyber threats, and money laundering. Stablecoin issuers will be required to build up a sufficiently liquid reserve at a 1:1 ratio and partly in the form of deposits, with the European Banking Authority (EBA) as the lead regulator.
Member State Autonomy
While the EU aims to harmonise regulations for crypto-assets, member states have the autonomy to implement their own rules for crypto-assets not covered by EU financial regulations. This has led to regulatory fragmentation, distorting competition in the Single Market and giving rise to regulatory arbitrage. The EU recognises the need to create a framework that supports innovation, fair competition, and a high level of consumer and investor protection in the crypto-asset markets.
The EU’s approach to cryptocurrency taxation aims to strike a balance between fostering innovation and ensuring regulatory compliance. By establishing a harmonised legal environment, the EU seeks to create a larger market for crypto-assets, promote issuance and operations within the EU, and develop EU-based DLT infrastructure.
Germany: A Leader in Crypto Regulation
In Germany, Europe’s largest economy, cryptocurrencies are gaining wider traction, with firms like DLT Finance offering a wide variety of regulated digital asset services, including brokerage, trading, custody, staking, and CeFi-DeFi bridging. Germany has proactively regulated cryptocurrencies, enacting a law in 2020 that mandates all cryptocurrency exchanges operating within its borders to obtain a licence from the Federal Financial Supervisory Authority (BaFin).
Tax-Free Long-Term Holdings
Germany is not a tax haven, nor is it a tax-free country on cryptocurrencies. However, it is a more favourable country for crypto investors due to its low tax rates on crypto exchanges. In Germany, cryptocurrency is considered Privatvermögen by the German Federal Central Tax Office. Such private money is tax-free as long as crypto earnings don’t exceed €600. This 0% tax rate is set out in Section 23 of the German Income Tax Act.
German income tax authorities are fairly friendly to any individual resident with crypto assets. You are not required to pay capital gains tax on crypto assets held for more than a year. So Germany-based crypto investors will not need to pay tax on sales of the likes of bitcoin and ether, as long as they’re held for more than a year. The BMF has also recently clarified that this year holding period also applies to crypto that you’ve lent or staked – so provided you’ve held your asset for more than one year, even if you’ve staked or lent it, it is tax free.
Business vs. Private Transactions
When you dispose of a private asset, like crypto, the tax rules change depending on how long you’ve held the asset for. If you’ve held your crypto for less than a year, you’ll pay Income Tax on any profits from a disposal. Disposals include selling your crypto for EUR (or any other fiat currency), swapping your crypto for another cryptocurrency, or spending your crypto on goods and services. However, if you have an annual net gain of less than €600 you do not need to file a tax return.
Section 15 of the German Income Tax Act lays out corporate cryptocurrency taxation in Germany. This section of the German Income Tax Act stipulates that there is no minimum holding period after which crypto tax exemption takes place. LLCs, public companies, and other corporate entities will need to consider the income tax implications of having extensive crypto holdings or if they foresee participating in mining or staking activities. If the company is a partnership, it is subject to income tax. In the same way any profits of a sole proprietor are subject to income tax.
Compliance Requirements
BaFin plays a pivotal role in the German crypto environment, overseeing the regulation of its markets, including cryptocurrency exchanges, brokers, and custodians. Germany has clear AML regulations that are applicable to cryptocurrency exchanges and service providers. These providers must implement Know Your Customer (KYC) procedures and monitor transactions to prevent money laundering and terrorist financing. They are also mandated to report suspicious activity to the Financial Intelligence Unit (FIU) via BaFin’s Suspicious Transaction Reporting System. The German Money Laundering Act (GwG) and the Regulation on Enhanced Duties of Care concerning the Transfer of Crypto Assets (KryptoWTransferV) are crucial for AML compliance.
Cryptocurrency exchanges in Germany offer various trading options such as spot trading, futures trading, and options trading. All exchanges operating in Germany must be licenced by BaFin and comply with AML and KYC regulations . Activities like custody, borrowing/lending, and yield/staking also come under financial services regulation.
France’s Progressive Crypto Tax System
In France, cryptocurrencies are treated as movable property and not as legal tender, influencing the taxation of digital currencies like Bitcoin, Ethereum, and other altcoins. If you sell cryptocurrencies and realise a gain, this is subject to capital gains tax.
France does not offer a tax exemption for long-term gains in cryptocurrencies. All gains, regardless of the holding period, are taxed at the standard flat rate of 30%. Similar to trading, staking cryptocurrencies can also lead to tax implications, with rewards or interest earned from staking treated as additional income and taxed at your personal income tax rate.
Flat Tax Introduction
The taxation of cryptocurrencies in France is based on a single flat tax, called the “flat tax” . Until recently, the flat tax rate on crypto capital gains was 30%, comprising 12.8% income tax and 17.2% social security contributions. However, as of January 1, 2023, investors have the option to be taxed using a progressive income tax scale between 0-45% instead of the flat tax.
Exemptions and Thresholds
If your total taxable crypto sales are less than €305 over the year, you are exempt from tax and have nothing to declare. This exemption threshold allows you to make small investments without worrying about taxes. It is also essential to declare your crypto accounts held outside France, as most exchange platforms are not French.
Certain events, such as exchanging or swapping crypto assets, gifting crypto assets, participating in ICOs and IEOs, receiving airdrops, bounties, hard forks, master nodes, lending, staking, DeFi activities, margin trading, future trading, and NFT transactions, are not considered taxable events in France. However, if you make a capital gain from these activities and realise it in fiat currency, it will create a taxable event.
Future Policy Direction
The change to allow progressive income tax rates is interesting for people with a tax bracket below 11%. This progressive scale is valid from 2023 but will only be applicable in 2024 for the 2023 return. The progressive income tax rates are as follows:
| Income Brackets | Rate |
| Up to €10,777 | 0% |
| €10,778 – €27,478 | 11% |
| €27,479 – €78,570 | 30% |
| €78,571 – €168,994 | 41% |
| More than €168,994 | 45% |
Additionally, the micro-BNC tax regime applies to most investors, including crypto miners and professional traders with less than €77,700 annual turnover for 2023. This regime calculates taxable profit from annual turnover, less a 34% tax-free allowance, meaning only 66% of profits are taxable using the progressive income tax brackets.
United Kingdom Post-Brexit Crypto Taxation
The growth of the cryptoasset market has created significant challenges to tax transparency frameworks like the Common Reporting Standard (CRS) that are integral to tackling tax evasion, tax avoidance, and non-compliance. Cryptoassets can be transferred and held without interacting with traditional financial intermediaries and without any central administrator having full visibility.
HMRC Guidelines
The UK government has introduced the Crypto-Asset Reporting Framework (CARF) to address these challenges. The primary purpose of the CARF is to provide HMRC with access to standardised information that will be used to help identify and tackle tax non-compliance, including by supporting those who want to get their tax right first time.
The CARF is a global framework, and the same rules will be implemented across all participating jurisdictions, meaning there will be one reporting regime to follow. This is preferable to multiple information regimes operating across different countries, which would create complexity for service providers and tax authorities alike.
To ensure the effective implementation of the CARF, the UK must ensure strong measures are in place to address instances of non-compliance by Reporting Crypto-Asset Service Providers (RCASPs) and Reportable Users. The government intends to introduce penalty provisions in the regulations implementing the CARF that are consistent, where appropriate, with its implementation of the Model Rules for Digital Platforms (MRDP).
Tax Treatment of Different Crypto Activities
The UK government has also amended the CRS to clarify the tax treatment of various crypto-related activities. The amended CRS clarifies that derivative financial instruments referencing cryptoassets are Financial Assets for CRS purposes, and it amends the definition of Investment Entity to include investing in cryptoassets as a type of activity that will bring an Entity within the scope of the CRS.
To avoid duplicated reporting under both the amended CRS and the CARF, there is a rule that, unless a Reporting Financial Institution elects otherwise, gross proceeds from the sale or redemption of Financial Assets are not required to be reported if such gross proceeds are reported by the Reporting Financial Institution under the CARF.
The UK government also considers there are potential benefits from extending CRS and CARF by making the UK a reportable jurisdiction, including streamlining third-party reporting requirements and preventing a two-tier system of third-party information requests.
The tax treatment of cryptocurrencies in the UK varies depending on whether the taxpayer is an individual or a company.
When individuals sell, trade, or spend cryptocurrencies, they are generally liable for CGT (Capital Gains Tax). The gain is calculated by deducting the cost basis (purchase price plus allowable costs) from the disposal proceeds. The CGT rates depend on the individual’s total taxable income. The Basic Rate Taxpayers is around 10% while the Higher and Additional Rate Taxpayers is around 20%. Individuals have also an annual CGT allowance (£12,300 for the 2023/2024 tax year). Gains below this threshold are not taxed.
If an individual’s cryptocurrency activities are deemed to be trading (e.g., frequent buying and selling), they may be subject to income tax rather than CGT. Income from mining or staking cryptocurrencies is typically subject to income tax.
Income tax rates are progressive; the Basic Rate is 20%, the Higher Rate is 40%, and the Additional Rate is 45%.
Companies engaged in trading cryptocurrencies must pay corporation tax on their trading profits. If the cryptocurrency is held as an investment, any gains from its disposal will be subject to corporation tax as chargeable gains. The corporation tax rate for the 2023/2024 tax year is 25% (although smaller companies with profits below £50,000 may be eligible for a lower rate).
Reporting and Record-Keeping
Individuals dealing with cryptoassets are responsible for keeping their own records for each transaction. These records can include paper (cold) wallets, electronic (hot) wallets, downloads of wallet activity from exchanges, and hardware (cold) wallets. Cryptoasset transactions usually occur on a public blockchain, so they can be viewed digitally and checked using records obtained from a wallet.
HMRC may request electronic records with full details of transactions and any supporting valuation records for the acquisition and disposal tax points. Individuals must keep records of the type of cryptoasset, date of the transaction, whether they were bought or sold, the number of units involved, the value of the transaction in pound sterling, the cumulative total of the investment units held, and bank statements and wallet addresses.
Cryptoasset exchanges may only keep records of transactions for a short period, or the exchange may no longer be in existence when an individual completes a tax return. Therefore, the onus is on the individual to keep their own records for each cryptoasset transaction.
Italy’s Approach to Taxing Digital Assets
Current Tax Framework
Italy initially recognised virtual currencies through Legislative Decree no. 90 of 19 June 2017, which transposed the EU’s anti-money laundering directive. However, until recently, there was no specific tax legislation on income derived from cryptocurrencies.
The Budget Law 2023 (Article 1, paragraphs 126 to 147 L. 197/2022) introduced a unified tax regulation for crypto-assets in Italy. Crypto-assets are defined as “a digital representation of value or rights that can be transferred and stored electronically, using distributed ledger or similar technology”.
According to the new law, capital gains and other income realised through the redemption, disposal, exchange, or holding of crypto-assets qualify as miscellaneous income for income tax purposes. The taxable base for capital gains is the difference between the sale price (or normal value for exchanges) and the purchase cost. Capital gains are subject to a 26% substitute tax if they exceed €2,000 in the relevant fiscal year.
The exchange of crypto-assets for goods/services, or for different types of crypto-assets (e.g., cryptocurrency for NFTs), is a taxable event. However, the exchange between crypto-assets with the same characteristics and functions is explicitly excluded from taxation.
Proposed Legislative Changes
The Italian Tax Authority (ITA) released Circular Letter No. 30/2023, providing clarifications on the taxation of crypto-assets and NFTs for income tax and VAT purposes. The circular aligns with the OECD’s Crypto-Asset Reporting Framework and the EU’s MiCA regulation.
Under the proposed changes, income derived from transferring NFTs representing intellectual works qualifies as professional income if the activity is deemed professional, or as miscellaneous income if not. The tax treatment of mining rewards and staking income depends on whether the activity is professional or not.
The Budget Law 2023 introduced the possibility for taxpayers to restate the value of their crypto-assets as of January 1, 2023, and pay a 14% substitute tax on that value. It also allows taxpayers to regularise previously undeclared crypto-assets and income by submitting a special declaration and paying a substitute tax.
Tax Treatment of Different Crypto Activities
For individuals carrying out professional activities involving crypto-assets, the income qualifies as professional income, subject to progressive personal income tax rates up to 43% (plus local surcharges up to 4%) on an accrual basis. The determination of a professional activity is based on factors like the number of transactions, turnover, lack of other income sources, and advertising efforts.
Capital losses exceeding €2,000 can offset capital gains in the same fiscal year, with the excess amount carried forward for four years. Resident individuals must disclose their crypto-asset holdings and income in their annual tax return, and a 0.2% stamp duty applies to the year-end value of crypto-assets.
For corporate entities, income from crypto-assets should be included in the taxable base for corporate income tax (IRES) at 24%, and regional production tax (IRAP) at 3.9%. Tax losses may be offset against gains in the same year, with the excess carried forward subject to an 80% limit.
The taxation of crypto-assets for VAT purposes depends on the nature of the transaction, as outlined by the VAT Committee in Working Paper no. 1060/2023. If the supply relates only to the NFT, it qualifies as a supply of services by electronic means; if it relates to the NFT and its underlying asset, the VAT rules applicable to the underlying asset will apply.
Spain’s Evolving Cryptocurrency Regulations
The Spanish government does not classify Bitcoin and other cryptocurrencies as fiat currency such as the Euro. Instead, it views them as property, which affects their tax treatment.
Recent Tax Reforms
In July 2021, Spain passed the Law on Measures to Prevent and Combat Tax Fraud, which forces centralised crypto exchanges to share customer information with the government. This is an important ruling for crypto investors in Spain as it takes away some of the perceived anonymity for crypto transactions.
Tax Treatment of Cryptocurrencies in Spain
In Spain, the tax treatment of cryptocurrencies differs for individuals and companies, with specific rules and rates applicable to each category.
For individuals, the primary tax considerations involve income tax (Impuesto sobre la Renta de las Personas Físicas – IRPF), capital gains tax, and wealth tax. Profits from the sale, exchange, or utilization of cryptocurrencies are subject to capital gains tax under the IRPF. The applicable rates for 2023 are as follows: up to €6,000, a rate of 19%; from €6,001 to €50,000, a rate of 21%; from €50,001 to €200,000, a rate of 23%; and over €200,000, a rate of 26%. Individuals can deduct the acquisition cost and related expenses when calculating the taxable gain.
Income derived from activities such as mining and staking cryptocurrencies is considered income from economic activities and is taxed under the progressive rates of the IRPF: up to €12,450 at 19%; from €12,451 to €20,200 at 24%; from €20,201 to €35,200 at 30%; from €35,201 to €60,000 at 37%; from €60,001 to €300,000 at 45%; and over €300,000 at 47%. Additionally, if cryptocurrency trading is deemed a business activity, it is taxed at the same progressive rates.
Individuals with significant net wealth are subject to the wealth tax (Impuesto sobre el Patrimonio). This tax applies to individuals with net wealth exceeding €700,000, excluding a primary residence valued up to €300,000. The rates for wealth tax vary by region, generally ranging from 0.2% to 3.5%. Furthermore, there is an obligation to report assets abroad using Form 720 if the total value of cryptocurrency holdings exceeds €50,000.
For companies, the tax treatment of cryptocurrencies is primarily governed by the corporate income tax (Impuesto sobre Sociedades – IS). Profits from cryptocurrency trading are subject to corporate income tax at a general rate of 25%. Newly established companies benefit from a reduced rate of 15% during their first two profitable years. Income generated from mining and staking activities is treated as business income and is similarly taxed at the corporate income tax rate.
Companies must accurately account for cryptocurrency transactions in their financial statements, valuing these assets at fair market value.
The value-added tax (VAT – Impuesto sobre el Valor Añadido – IVA) also plays a role in the tax treatment of cryptocurrencies. The exchange of cryptocurrencies is exempt from VAT; however, when companies accept cryptocurrency as payment for goods or services, VAT applies in the same manner as it does for transactions conducted with traditional fiat currency.
Both individuals and companies are required to maintain detailed records of all cryptocurrency transactions, including dates, amounts, and the value in euros at the time of each transaction. Accurate record-keeping is essential for calculating tax liabilities and filing precise tax returns with the Spanish tax authorities (Agencia Tributaria).
Penalties for Non-Compliance
It is just as important to remember that failing to declare any crypto gains or income can now result in serious consequences, including hefty fines and even prison time. The penalties for tax violations in Spain, whether accidental or on purpose, can be quite strict with fines ranging up to 150% of the undeclared amounts . Residents of Spain that try to avoid paying taxes exceeding 120.000€ may even face a prison sentence. The penalties for crypto tax evasion are steep – up to five times higher than the amount you failed to declare and potentially prison time too.
Cross-Border Implications of Crypto Taxation
The rapid growth of the crypto-asset market has posed significant challenges for tax authorities in ensuring tax transparency and combating tax evasion and avoidance. The decentralised and mobile nature of crypto-assets, combined with the lack of uniform tax legislation across jurisdictions, has led to an uneven treatment of the crypto sector within the internal market.
Double Taxation Issues
One of the key concerns in the taxation of crypto-assets is the potential for double taxation. As crypto-assets can be traded and held across multiple jurisdictions, there is a risk of the same asset being taxed in multiple countries. This issue arises due to the lack of clear guidelines and tax treaties specifically addressing the treatment of crypto-assets.
To mitigate this risk, it is crucial for countries to establish clear tax policies and collaborate on developing international standards for the taxation of crypto-assets. This could involve amending existing tax treaties or negotiating new agreements that address the unique characteristics of crypto-assets and provide mechanisms for preventing double taxation.
Exchange of Information
Effective exchange of information between tax authorities is essential for ensuring tax compliance and preventing tax evasion in the crypto-asset sector. The European Commission recognises the need for a harmonised reporting framework to facilitate the exchange of information on crypto-asset transactions.
The proposed EU Crypto-Asset Reporting Framework (CARF) aims to introduce a reporting framework for crypto-asset transactions, closely following the provisions of the OECD’s CARF . The framework identifies two types of entities that would be obliged to report information to local authorities: Crypto-asset providers and Crypto-asset operators.
Reporting Crypto-Asset Service Providers (RCASPs) would need to report exchange transactions and transfers of reportable crypto-assets, both domestic and cross-border transactions. The data to be reported includes information about the users, the crypto-assets traded, and the transaction details.
Tax Treaty Considerations
Existing tax treaties may need to be amended or updated to address the taxation of crypto-assets in cross-border scenarios. The OECD’s Model Tax Convention and its Commentary provide guidance on the allocation of taxing rights between jurisdictions, but they may need to be adapted to account for the unique characteristics of crypto-assets.
One key consideration is the classification of crypto-assets for tax purposes. Depending on whether they are treated as property, financial assets, or something else, the applicable tax treaty provisions may differ. Tax authorities and policymakers will need to collaborate to develop a consistent approach to the classification of crypto-assets and their treatment under tax treaties.
Additionally, tax treaties should address issues such as the taxation of mining and staking rewards, the treatment of crypto-to-crypto transactions, and the prevention of double taxation on capital gains or income derived from crypto-assets held or traded across multiple jurisdictions.
To facilitate the exchange of information and ensure tax compliance, it may also be necessary to update tax treaty provisions related to the exchange of information and mutual assistance in the collection of taxes.
Challenges in Implementing Crypto Tax Policies
Valuation Issues
Calculating the fair market value (FMV) of cryptocurrencies is analogous to valuing marketable securities like stocks and bonds, but with additional challenges. Unlike traditional exchanges, virtual currency markets operate 24/7, making it impossible to calculate FMV under the same valuation rules. Moreover, crypto prices can fluctuate rapidly, sometimes within minutes or hours, making it difficult to accurately value digital assets at the time of sale or an owner’s death. Estate planners may need to collaborate with appraisers or financial professionals to determine the FMV of digital assets and develop strategies for selling them over time to mitigate market volatility.
Anonymity Concerns
The element of anonymity inherent in crypto assets raises enforcement issues associated with cash transactions. Cryptocurrencies, like cash, do not inherently reveal the personal or business identity of those involved in a transaction. Holders exercise control through a private ‘key’ or address held in a ‘wallet,’ but transactions reveal only a public address, from which the identity cannot be inferred. This ‘quasi-anonymous’ nature of cryptocurrencies, combined with their transparency and extra-territoriality, amplifies the difficulties posed by anonymity.
The most fundamental difficulty in taxing crypto assets is their ‘pseudonymous’ nature, making it extremely difficult to link transactions with individuals or firms, potentially enabling tax evasion. While centralised exchanges can be subject to ‘know your customer’ tracking rules and withholding taxes, reporting obligations could drive people towards decentralised exchanges or peer-to-peer trades, which are challenging for tax administrators to penetrate.
Technological Limitations
Limited information on crypto activities, pseudo-anonymity, and scant tax data due to the lack of automatic exchange of information pose significant challenges for tax authorities. Empirically quantifying the impact of cryptocurrencies on tax compliance and transparency is difficult, although blockchain technology might help improve tax compliance and transparency.
Given the complexity of challenges posed by pseudonymity, the rapidity of innovation, vast information gaps, and uncertainties ahead, the tide has not yet turned in incorporating crypto properly into the wider tax system. Addressing these challenges will require international cooperation, harmonised reporting frameworks, and effective implementation of regulatory measures.
Conclusion
The exploration of cryptocurrency taxation across Europe reveals a complex and evolving landscape. Each country’s approach has an impact on the broader regulatory environment, highlighting the need for harmonisation and collaboration. The diverse strategies employed by Germany, France, the UK, Italy, and Spain to tackle the challenges posed by digital assets demonstrate the ongoing efforts to balance innovation with regulatory compliance and tax transparency.
To wrap up, the cross-border implications and implementation challenges underscore the need to develop comprehensive and adaptable tax policies for cryptocurrencies. As the crypto market continues to grow and evolve, policymakers and tax authorities must work together to address issues such as valuation, anonymity, and technological limitations. This collaborative effort is crucial to create a fair and efficient tax system that can keep pace with the rapidly changing world of digital assets.
Some References
[1] – https://eucrim.eu/news/new-rules-for-crypto-assets-in-the-eu/
[2] – https://finance.ec.europa.eu/digital-finance/crypto-assets_en
[3] – https://www.europarl.europa.eu/RegData/etudes/BRIE/2023/753930/EPRS_BRI(2023)753930_EN.pdf
[6] – https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto10400
[7] – https://www.europarl.europa.eu/RegData/etudes/BRIE/2023/739310/EPRS_BRI(2023)739310_EN.pdf
[8] – https://www.europarl.europa.eu/cmsdata/241925/Andreas%20Thiemann%20Presentation.pdf
