The German tax authorities are paying closer attention to crypto gains. According to the LBF NRW (State Office for Combating Financial Crime of North Rhine-Westphalia), the coordinated analysis of a collective information request for crypto transaction data has now begun. For investors who have previously bought, sold, exchanged, staked, lent, or deposited and withdrawn cryptocurrencies via crypto exchanges, this is a clear indication that they should review their tax situation.
Collective information request: Around 4,000 crypto transaction records under review
The LBF NRW announced on 9 March 2026 that more than 80 representatives from Germany and Austria met in Düsseldorf to exchange experience on the taxation of crypto gains. According to the press release, participants included the tax investigation authorities, tax administration, the Federal Central Tax Office (BZSt) and the Federal Financial Supervisory Authority (BaFin).
Particularly important: According to the tax authorities, the meeting marks the start of the coordinated analysis of a recent collective information request covering around 4,000 crypto transaction records.
What is the current crypto data package about?
The press release does not identify the specific trading platform from which the approximately 4,000 transaction records originate.
Only the following has been confirmed so far:
- The analysis is being coordinated with the involvement of tax investigation and tax administration authorities from the German federal states.
- Authorities from Austria also took part in the exchange of experience.
- This indicates that the issue is being addressed not only at regional level, but also across Germany and in cross-border cooperation.
There has been speculation within the professional community that the data may originate from a well-known crypto trading platform. However, until this is officially confirmed by the tax authorities, this should not be treated as an established fact.
What data could be analysed?
The press release does not specify which data fields are included. However, based on practical tax experience and the way such information requests are typically handled, the following data could potentially be analysed:
In the context of crypto-related information requests, the most relevant data is generally that which enables the identification of the taxpayer and the tax assessment of their transactions. This may include, for example:
- Name and contact details of the users
- Bank account details or payment information
- Dates and times of purchases and sales
- Type and quantity of the crypto-assets traded
- Transaction values in euros or another currency
- Deposits and withdrawals
- Wallet addresses
- Transaction histories
- Platform or account information
This list is a tax-related assessment and does not indicate which data is actually included in the current data package.
However, one point is particularly important: Even a limited amount of initial data may be sufficient to trigger further enquiries from the tax authorities. In particular, deposits to and withdrawals from an exchange to external wallets may prompt the tax authorities to ask how the crypto-assets were subsequently used.
Information requests and DAC8: What is the difference?
The current crypto data package is based on a collective information request. This type of request is an investigative tool used by the tax authorities to establish the relevant facts. The authorities request specific data from a particular source, such as a platform or service provider. The data is then analysed and may be shared with the responsible tax offices or investigation authorities.
This should be distinguished from DAC8 and the German Crypto-Asset Tax Transparency Act. Unlike a collective information request, these do not relate to a single investigation by the tax authorities. Instead, they establish a structured, statutory framework for the reporting and exchange of information.
In the future, crypto-asset service providers will be required to report certain information about their users and their transactions. These reporting obligations will apply for the first time to the 2026 calendar year. According to the Federal Central Tax Office (BZSt), the first reports covering 2026 must be submitted by 31 July 2027.
Put simply, a collective information request is a targeted request for data that already exists. DAC8 and the Crypto-Asset Tax Transparency Act, on the other hand, establish a permanent reporting framework for crypto-assets.
For taxpayers, this means that the current analysis relates to past transactions. The new reporting obligations will additionally ensure that crypto transactions become more systematically and automatically visible to the tax authorities in the future.
Why is this relevant for tax purposes?
Crypto transactions are often more complex for tax purposes than many investors initially assume. Tax implications do not arise only when converting crypto-assets back into euros. Exchanging one cryptocurrency for another can also be a taxable event. Depending on the individual circumstances, the same may apply to NFT sales, airdrops, staking, lending, or other income derived from crypto-assets.
For individuals, gains from the disposal of crypto-assets may be taxable as private disposal transactions, particularly if the period between acquisition and disposal does not exceed one year. If crypto-assets are held for more than one year, a sale by a private individual may generally be tax-free.
However, the details are crucial: the acquisition date, disposal date, crypto-to-crypto exchanges, wallet transfers, transaction fees, and the correct allocation of individual crypto-assets.
In particular, where multiple exchanges, decentralised wallets, crypto-to-crypto exchanges, and incomplete documentation are involved, preparing the tax records can become a complex and time-consuming process.
What happens if the tax authorities contact me?
If you receive a letter from the tax office because your data appears to be included in a crypto data package, you should not respond hastily. In many cases, the initial purpose is to clarify whether, and to what extent, taxable crypto gains or other crypto-related income have been properly declared.
It is important to take a structured approach:
- Review the letter carefully: Is it a routine enquiry, a tax audit, a tax crime investigation, or does it already involve the tax investigation authorities?
- Secure all your crypto records: This includes exchange exports, wallet addresses, transaction histories, bank statements, tax reports, emails, and records of acquisition costs.
- Determine which tax years are affected and whether any tax returns were incomplete or incorrect.
- Before providing a substantive response, clarify whether a correction of your tax return or a voluntary disclosure is still possible.
- Any response to the tax authorities should be coordinated with tax and legal advisers, particularly where tax crime issues may arise.
Particularly important: If a tax crime investigation has already been initiated, or if the offence has already been discovered and the taxpayer could reasonably have been aware of this, a voluntary disclosure may no longer provide relief from criminal prosecution. For this reason, you should not wait until the tax authorities have fully investigated the matter.
Voluntary disclosure for crypto-related tax matters: Why acting quickly is important
Anyone who has failed to declare taxable crypto gains or other crypto-related income in the past should seek advice at an early stage to determine whether a voluntary disclosure or a correction of a tax return may be appropriate.
A valid voluntary disclosure must be complete, timely, and accurate. This can be particularly challenging in relation to crypto-assets. In most cases, it is not sufficient to declare only selected gains retrospectively. Instead, all relevant tax matters that are still within the statutory limitation period must be fully reviewed and disclosed.
This includes, in particular:
- Purchases and sales
- Crypto-to-crypto exchanges
- NFT transactions
- Mining
- Staking
- Lending
- Airdrops
- Income from DeFi protocols
- Fees and transaction costs
- Transfers between exchanges and wallets
- Previously undeclared foreign matters
ACCONSIS experts in crypto tax advisory support clients with:
the tax and criminal tax law assessment of such cases. As a law firm and tax advisory practice, we combine the tax reconstruction of crypto transactions with the legal assessment of tax correction obligations, voluntary disclosures, and potential defence risks.
Our practical recommendation
The recent LBF NRW press release demonstrates that crypto transactions are now firmly on the radar of the German tax authorities. Through collective information requests, historical transaction data is already being analysed. From 2026, DAC8 and the Crypto-Asset Tax Transparency Act will introduce an additional automated reporting framework.
Anyone who has not declared, or has not fully declared, their crypto transactions should take action now. This is particularly important where large transaction volumes, multiple platforms, external wallets, or undocumented crypto-to-crypto exchanges are involved.
If you have already received a letter from the tax office, you should proceed with particular caution. Contact us before providing any information to the tax authorities. We will assess your tax obligations, determine whether a voluntary disclosure or correction of your tax return is still possible, and advise you on the most appropriate and legally compliant way to resolve the matter.
Have you received a letter from the tax office regarding your crypto transactions?
ACCONSIS provides tax and criminal tax law advice tailored to your case – from reconstructing your crypto transactions to voluntary disclosure or a tailored defence strategy.
Your ACCONSIS contact
Dr. Christopher Arendt
Lawyer, specialised lawyer for tax law
Managing Director of ACCONSIS
Service phone
+49 89 547143
or via email
c.arendt@acconsis.de
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