Proving the origin of crypto assets means making it traceable, with documents, where your crypto came from, when it was acquired and which route it has taken. Paucitas investigates that route on the blockchain, combines it with your exchange and bank data, and records it in a report that a bank, the Dutch Tax Administration, an accountant or a civil-law notary can check. Paucitas gives no tax or legal advice itself and holds no funds; the report is the substantiation your adviser works with. A standard investigation is usually ready within three working days.
On this page
- What exactly does the tax authority ask for in a request for information about crypto?
- What proof of crypto holdings is accepted?
- What is a balance specification on the reference date, and how do I make one?
- When is an exchange annual statement not enough?
- How do I prove origin if I no longer have exchange history?
- What does a bank ask for on a deposit originating from crypto?
- What does an accountant need for the financial statements?
- What does a civil-law notary ask for on a gift or an estate?
- What changes with DAC8 from 1 January 2026?
- How do I substantiate crypto holdings of a company or its director-shareholder?
- What is in an origin report, and how long does it take?
- What cannot be proven?
What exactly does the tax authority ask for in a request for information about crypto?
In practice, a request for information about crypto asks for three things: which holdings you had on the reference date, where those holdings came from, and how those two can be reconciled. Concretely, it asks for an annual statement from every exchange, a balance specification per wallet and per coin on 1 January, and the underlying CSV export or wallet export that makes those figures traceable.
The inspector does not only test the amount, but the traceability: can an outsider work your declaration back to source data, step by step? With one exchange and one wallet you can usually manage that yourself. With several wallets, missing years or an exchange that no longer exists, a gap appears that your own overview will not close.
A request for information from the Dutch Tax Administration is based on article 47 of the General State Taxes Act (Algemene wet inzake rijksbelastingen, AWR). That provision sets no fixed statutory deadline: the inspector states a deadline in the letter, and it has to be reasonable. The data requested must be provided clearly, unequivocally and without reservation.
If the request is not complied with, the inspector can issue an information order under article 52a AWR. Once that becomes final, it can affect the burden of proof in later proceedings. The Tax Administration can also enforce compliance through the civil courts.
Importantly, the duty to provide information does not lapse when the seven-year retention period of article 52 AWR has expired. The fact that an exchange no longer exists, or that the matter concerns old years, does not release you from the obligation to supply the data requested.
Source: articles 47, 49 and 52a AWR, and the case law on the relationship between the duty to provide information and the retention period.
Where the administration for those years is missing, the blockchain does remain available. Transactions stay visible there, even years later, and together with the accompanying documents they can be worked back into a traceable overview.
Further reading: crypto assets and your tax return and the term box 3 and crypto.
What proof of crypto holdings is accepted?
There is no party that issues official proof of crypto holdings. No authority confirms your balance the way a bank issues an account statement. What is accepted is a set of source data that confirm one another: the exchange annual statement, a balance specification on the reference date, the CSV export of transactions, and publicly verifiable blockchain data through which those transactions can be found.
A Paucitas report adds the link you cannot supply yourself: verification that those source data match what is actually on the blockchain, and a chronological overview showing the route the holdings took. That is the difference between a declaration and a substantiation.
See also: asset verification and origin of assets.
What is a balance specification on the reference date, and how do I make one?
A balance specification is an overview of all holdings on one fixed date, broken down per wallet and per coin. For box 3 that date is 1 January, the reference date. A total amount is not enough; the specification has to be traceable per address and per coin.
You build that specification in four steps:
- List all wallets and exchange accounts, including the ones you no longer use.
- Obtain the annual statement and the CSV export from each exchange for the year concerned.
- For each self-custodied wallet, make a wallet export of the addresses and the balances on the reference date.
- Convert the balances into euros at the rate on the reference date and document which price source you used.
The price source is often overlooked. Many people work from a figure they kept themselves, without recording which rate was used at which moment. For the traceability of the declaration that is necessary, and if questions are asked it will be requested.
When is an exchange annual statement not enough?
An exchange only records what happens on that exchange. As soon as holdings move outside it, the annual statement is by definition incomplete. That applies in these situations:
- You held assets outside the exchange, in self-custody.
- You used several exchanges and transferred between them.
- The exchange no longer exists.
- The statement is missing one or more years.
- You received crypto from a third party instead of buying it.
- The declaration relates to a year in which the exchange did not provide a complete statement.
- The holdings were acquired through mining or staking.
- The holdings were acquired through a private transaction between individuals.
In each of those cases the link is missing between what the exchange shows and what the holdings actually were. That link can be established on-chain, because transfers between wallets and exchanges are publicly verifiable.
See also: exchange and tracing crypto.
How do I prove origin if I no longer have exchange history?
Where the exchange history is missing, the investigation moves to the blockchain itself. From the transaction history of an address it can be established when holdings came in, what type of service provider they came from and how they moved afterwards. That does not produce names, but it does produce a timeline and a route.
What is needed in addition are your own documents linking that timeline to you: bank statements of deposits to the exchange, old emails with account confirmations, or a screenshot showing an address you can demonstrate you control. The combination of those two sources makes the whole traceable.
Further reading: manual blockchain investigation versus automated tools.
What does a bank ask for on a deposit originating from crypto?
On a deposit originating from crypto, a bank asks about the origin of the funds and the route the money has taken, because the bank itself has an obligation to establish that origin. In practice the bank asks for proof of purchase, an overview of the intermediate transactions and an explanation of why the amount differs from what was originally invested.
A blocked account is rarely released on the basis of an explanation alone; the bank wants to be able to check the underlying data. A report that records the route chronologically and refers to publicly verifiable transactions is the most useful document for that.
Further reading: proving origin to your bank, when a bank blocks the account and the term KYC and AML.
What does an accountant need for the financial statements?
For the financial statements an accountant needs three things: the balance per coin on the balance sheet date, the valuation with the price source used, and substantiation that the company actually controls those holdings. That last point is why a screenshot is not enough: it proves a balance, not control.
With business crypto holdings, the separation between private and business assets comes on top of that. Where holdings on a single address are mixed, that separation has to be reconstructed from the transaction history before anything can appear on the balance sheet.
Further reading: substantiating crypto origin for your accountant.
What does a civil-law notary ask for on a gift or an estate?
Where crypto forms part of a gift or an estate, a civil-law notary asks about two things: which holdings existed on the reference date and who was able to dispose of them. Without that second answer it cannot be established what exactly is being gifted or inherited.
Concretely, it comes down to three elements:
- An overview of the holdings per wallet and per coin on the date of death or of the gift.
- A valuation of those holdings on that same date, stating the price source used and the moment applied. A crypto price moves within a single day; the documents therefore have to show which moment was taken.
- A record of who was able to dispose of the holdings: on which addresses they were held, whether these were self-custodied or with an exchange, and what shows that the deceased or the donor had control over them.
That last element is rarely self-evident with crypto, because holdings at an address are not held in anyone’s name. That someone was able to dispose of a wallet follows from the combination of the transaction history, its reconciliation with their bank and exchange data, and the presence of the access means. The investigation records what can and what cannot be derived from that.
With an estate there is the further question of whether the holdings are still accessible. That question belongs in the investigation and not in an assumption: the degree of access determines whether there is a claim or an available asset.
What the investigation delivers is a factual determination of holdings, valuation and power of disposal on the reference date. The conclusions the notary or your own adviser draws from it are theirs; Paucitas gives no tax or legal advice.
Further reading: gifting or inheriting crypto and crypto in an estate.
What changes with DAC8 from 1 January 2026?
From 1 January 2026, crypto-asset service providers in the EU must collect and verify data on their customers and their transactions and report it annually to the tax authority of their country. Those data are then exchanged automatically between the tax authorities of the EU member states. The first report, covering calendar year 2026, must be filed by 31 January 2027 at the latest. It concerns identification data of the user and the transactions carried out, including purchases and sales, exchanges and transfers.
In tax terms nothing changes: crypto holdings already had to be declared in box 3 before this. What changes is that the Tax Administration can now place your declaration alongside the exchange’s data.
Crypto you hold in self-custody does not fall under that reporting obligation. That is exactly where the difference arises that you have to be able to explain yourself: the tax authority sees what is held at the exchange, not what is held outside it. If your declaration differs from the data supplied, questions follow, and questions are answered with traceability.
The Dutch implementation is laid down in the Act implementing the EU directive on the exchange of information on crypto-assets (Stb. 2026, 79), which entered into force on 11 April 2026 with retroactive effect to 1 January 2026. See also the explanation by the Dutch Tax Administration: https://over-ons.belastingdienst.nl/meer-zicht-op-cryptotransacties/
How do I substantiate crypto holdings of a company or its director-shareholder?
For a company or its director-shareholder (dga), the substantiation consists of three layers: which addresses belong to the business, which to private assets, and which transactions took place between the two. That third layer is almost always the problem, because transfers between private and business were rarely recorded in the early years.
The investigation reconstructs that separation from the transaction history and records, per address, on what grounds it is allocated to the business or to private assets. That allocation is a factual determination; its tax consequences are for your own adviser.
Further reading: crypto on the balance sheet for entrepreneurs.
What is in an origin report, and how long does it take?
A Paucitas report follows a fixed structure. Not every report contains every part, the scope varies with the case file, and the layout is tailored to the purpose of the report.
- Background and description of the assignment
- Questions to be answered
- Scope of the investigation
- Assumptions
- Data supplied
- Sources consulted
- Method in outline
- Verification and quality assurance
- Reservations and limitations
- Findings per element
- Chronological overview
- Analysis and coherence
- Conclusion
- Declaration of independence
- Appendices
Part fourteen, the declaration of independence, is the part that matters most with a question of origin. Paucitas does not work on the instructions of an exchange, a software vendor or a platform, and has no interest in the outcome of the investigation. That is precisely what a bank, an inspector or a judge wants to know about a substantiation.
Turnaround time. Depending on the size of the case file and the urgency, a Paucitas investigation takes between one working day and two weeks. An urgent report can be delivered within one working day and, in exceptional cases, the same day. A standard investigation is usually ready within three working days. For case files with many transactions, several wallets or missing history, the turnaround time rises to around two weeks. A surcharge applies to urgent assignments.
Costs. Paucitas works on a fixed fee based on your situation. Sometimes an hourly rate is agreed instead, but the hours are always fixed in advance, so you are never faced with surprises. No investigation is started before the costs have been discussed and agreed.
How does an origin investigation proceed, step by step?
An origin investigation runs through the following steps. Which steps arise, and in which order, can vary with the type of report and the question asked.
- Intake. You set out the question and the purpose: bank, tax authority, accountant, notary or proceedings. The purpose determines the scope.
- List of data required. Data can be supplied digitally or at our office. For each case you receive a list setting out which data is needed. Where necessary, Paucitas guides you through collecting and supplying it.
- Analysis. The exports supplied are placed alongside the publicly verifiable blockchain data and traced back transaction by transaction.
- Verification. Paucitas uses no automated analysis software, in any role. Every transaction and every transaction hash is verified individually before it is included in a report.
- Reporting. Delivery according to the structure above, with the reservations and limitations stated explicitly.
- Explanation and follow-up. Where the case calls for it, the report is explained to your lawyer, accountant, civil-law notary, the court or the authority handling the matter. If new data becomes available later, the report can be supplemented. What is appropriate here depends on the type of investigation and the arrangements made.
What role do the tax authority, banks and regulators play?
The Tax Administration asks the question and tests the answer, but supplies no proof of your holdings itself. A bank asks the origin question out of its own obligation and assesses your documents, but does not investigate for you. Regulators supervise crypto-asset service providers, not private declarations.
Rules such as MiCA and the licensing requirement for crypto-asset service providers apply to the providers and exchanges you deal with, not to Paucitas: Paucitas is not a crypto-asset service provider, is non-custodial and holds no funds. Where those rules are relevant is in what your exchange asks of you and which data that exchange records about you.
The work of Paucitas begins where those parties stop: making traceable the data you have to supply yourself.
What cannot be proven?
This section is deliberately complete. What an investigation cannot do determines the value of what it can.
- Paucitas does not independently establish who is behind a crypto address. What is recorded is which service provider or party the funds went to, so that the information can be followed up through the proper channels.
- Transactions that took place off-chain, such as cash payments or internal bookings within an exchange, are not visible in blockchain data. They are only included where underlying documents are available.
- Where mixers or privacy-focused networks are used, the chain cannot always be followed in full. In that case the report states explicitly up to which point the route can be established.
- A Paucitas report confines itself to factual observations and the investigation of them.
- Paucitas gives no tax or legal advice.
- Paucitas makes no commitment about the outcome of an investigation.
- Paucitas holds no funds itself and carries out no transactions on behalf of clients.
Frequently asked questions
Why is my bank asking about the origin of my crypto?
Because the bank is itself required to establish the origin of incoming amounts. The question is not a suspicion but a compliance obligation. What the bank needs is a traceable route from purchase to payout.
What if I cannot prove the origin?
Then it is recorded up to which point the route can be established and where the substantiation stops. That too is a usable result: it makes the gap explicit instead of unstated, and for an inspector or a bank that is easier to work with than an incomplete overview without explanation.
Does Paucitas issue official proof of crypto holdings?
No. There is no authority or party that issues such proof. Paucitas delivers a report that makes your own declaration verifiable and traceable.
What is the difference between an annual statement and a balance specification?
An annual statement comes from the exchange and shows what happened there. A balance specification shows all holdings on one reference date, per wallet and per coin, including holdings outside that exchange.
How long does an origin investigation take?
A standard investigation is usually ready within three working days. With many transactions, several wallets or missing history, that rises to around two weeks. An urgent report can be delivered within one working day.
Does Paucitas work with software from a vendor?
Paucitas uses no automated analysis software, in any role. Every transaction and every transaction hash is verified individually before it is included in a report.
Can I make a start on this myself?
Yes. List your wallets and exchange accounts, obtain the annual statement and the CSV export from each exchange, and make a wallet export on the reference date for each self-custodied wallet. If you run into a missing year or a vanished exchange, that is where the investigation begins.
How quickly does Paucitas respond to a question?
Paucitas usually responds within a few minutes to an hour, and in almost all cases the same working day.
Which pages belong to this topic?
Terms
- Origin of assets — what the term means and when it comes up.
- Asset verification — establishing that declared holdings really exist.
- Box 3 and crypto — the reference date and the declaration.
- KYC and AML — why banks and exchanges ask this question.
- Money laundering — where the origin question comes from.
- Exchange — which data an exchange records about you.
Situations
- Proving origin to your bank — what the bank actually asks for.
- The bank blocks the account — what is needed then.
- Substantiating crypto in box 3 — the declaration and the follow-up questions.
- Substantiation for your accountant — what the financial statements require.
- Crypto on the balance sheet — separating private and business.
- A mortgage with crypto — what a mortgage lender asks.
- Gifting or inheriting crypto — origin and valuation.
- Crypto in an estate — holdings and access.
- Manual investigation versus tools — why verification is handwork.
Related topics
What can you do yourself right now?
Start by establishing what you still have: which exports, over which years, per wallet and per exchange. If a year or an exchange is missing, you know exactly where the investigation has to begin.
What you can supply
An investigation starts from a single starting point. That can be a transaction, an address, a photo or screenshot of a wallet, or the communication you had with a party. Even without a complete administration, more can usually be established than people expect.
What also helps, depending on your situation:
- statements and exports from the exchanges where you hold an account
- addresses of your own wallets
- bank statements for the period concerned
- correspondence, messages and screenshots
Which data your case file requires differs from case to case. After a first conversation you receive a list tailored to your situation.
Data can be supplied at our office or digitally by various methods.
Paucitas usually responds within a few minutes to an hour, and in almost all cases the same working day. Paucitas can be reached by telephone 24/7 on +31 20 244 5774.
About the author
R.T. (Tyler) Dijst is director and co-founder of Paucitas and runs the operation. He safeguards the quality and consistency of case handling and is involved in the expert stage of complex matters. His work focuses on complex blockchain investigation: tracing intricate transaction flows, analysing wallets and mapping how funds are routed across the chain. He also assesses the authenticity of physical crypto coins and identifies counterfeit or imitation specimens.
Paucitas is a specialist firm for cryptocurrency and blockchain. Investigation is our daily practice: hundreds of case files have been handled to date, ranging from individual matters to investigations for lawyers, public authorities and companies.