My crypto is held by a foreign provider, what changes for me with the international reporting standard?

What is the international reporting standard for crypto?

The international reporting standard for crypto, known as CARF, is an OECD standard under which providers of crypto services report data on their customers’ transactions to the tax authority, so that countries can exchange that data with each other. Within the European Union that standard has been implemented in the directive known as DAC8.

According to the European Commission, DAC8 is based on the OECD standard CARF, the rules have applied since 1 January 2026 and the first reporting on that year must be made between 1 January and 30 September 2027 (European Commission on DAC8). Providers collect data on the transactions of their customers living in the European Union for this purpose, and national tax authorities exchange the data of residents of other member states with each other.

For you as a holder the timeline is concrete. For 2026, providers are already keeping track of what they will have to report, and by 30 September 2027 at the latest the first report has been made. What you record yourself in that period determines whether you can later place a report next to your own data. How overview and tax return fit together in general can be read on the page proving the origin of assets.

What DAC8 involves exactly is briefly explained in the glossary under DAC8. This blog is about what that exchange means if your provider is not based in the Netherlands.

What changes if your provider is abroad?

If your provider is abroad, the report on your transactions can reach the Dutch tax authority via the tax authority of that country, which previously did not happen as a matter of course. The route differs per situation:

• Provider in another EU member state: the provider reports in its own member state, and that member state exchanges the data of Dutch residents with the Netherlands.
• Provider outside the EU active in the EU without a European authorisation: according to the European Commission, that provider must register in one member state for these reports.
• Provider outside the EU without European activities: whether data is reported depends on the arrangements between that country and the Netherlands.
• Own wallet: a wallet you manage yourself has no provider that reports; the balance is, however, on the chain.

The European Central Bank points out that regulation of crypto-assets is fragmented worldwide, leaving room for moving to less regulated places and for risks that cross borders (ECB on blind spots in crypto markets). For you as a holder, that fragmentation means that not every provider will report in the same way and at the same time. Precisely because of this, the picture that emerges at the tax authority under the international reporting standard can be incomplete or unbalanced.

If you hold assets with more than one provider, several reports about you can therefore arise, from different countries and at different times. Each of those reports describes a part. The whole only emerges when you place the parts next to each other yourself, including the transfers between providers and your own wallets.

Why does your evidential position under the international reporting standard matter more than the report?

Your evidential position matters more than the report, because a report only shows what one provider knows about your transactions, while you need to be able to explain how your total holdings were built up. A report is a snapshot from one party; your substantiation connects all parties and wallets with each other.

Three differences keep recurring in practice. A provider reports what happened with it and does not know that you bought the coins elsewhere earlier. A provider does not report transfers between your own wallets. And a provider uses its own valuation, which may differ from the price you used yourself. Paucitas sees that especially for holders with assets at several providers, the reports are each correct on their own but together do not give a conclusive picture.

The limit. Paucitas does not give tax or legal advice.

What you must declare and how remains a question for your adviser. What we record is the factual basis on which that question can be answered.

Case. A business owner held crypto at an exchange outside the European Union, at a provider in another member state and in his own hardware wallet. He had a picture of each location, but no overview in which the three came together.

When the reference date overview was drawn up, it turned out that the exchange outside the EU had credited staking rewards internally that were missing from his own records. In addition, part of the holdings at the European provider had earlier been deposited from his own wallet, which a report from that provider would show as new inflow. With the overview, both points were established, with source and date, before any report had been exchanged.

What does a reference date overview look like?

A Paucitas reference date overview records per provider and per wallet which holdings there were on a given date, at what value and on the basis of which source. It is structured so that it can be placed line by line next to a provider’s report.

1. Per provider: name, country of establishment, account identifier and the quantity per crypto-asset on the reference date, with the export or statement as source.
2. Per own wallet: the addresses and the balance on the reference date as recorded on the chain.
3. Valuation: the price used, the source of that price and the time at which it was determined.
4. Reconciliation: the transfers between providers and own wallets since the previous reference date, with transaction hash.
5. Accountability: the source per line, and where a piece of data is missing, an explicit statement to that effect.

How to record crypto holdings on a reference date is worked out further on the question page recording crypto holdings on a reference date. For business owners with crypto privately or on the balance sheet, the approach is on the page for directors and business owners.

What this means for anyone now considering an investigation

Anyone now considering an investigation is best advised to have a reference date overview recorded first, because that overview can later be placed next to any report. Under the international reporting standard, the data on 2026 will only be exchanged in 2027, and the exports and prices you need for it are still easy to obtain now.

Data is supplied digitally or at the office. Per case a delivery list is provided which states what data is needed. Where necessary Paucitas guides the collection and delivery of that data.

Paucitas works with a fixed fee based on your situation. Sometimes, by agreement, we use an hourly rate, but the hours are always fixed in advance, so that you are never faced with surprises. No investigation is started until the costs have been discussed and approved.

If you want your holdings with foreign providers and in your own wallets recorded per reference date, Paucitas draws up the overview you can place next to a report; see source of funds. The questions that come up most often in a verification for box 3 can be read in the related blog box 3 and crypto: the most frequent verification questions. For your own situation, contact Paucitas.