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ISBN: 9789403545295
Published: March 2026
Format: Hardcover
Language: English
Publisher: Kluwer Law International
This landmark study is the first to critically analyse whether international standards for the exchange of information in tax matters are adequate to cover crypto assets and cope with their inherent challenges. As crypto assets move into the mainstream and become increasingly entangled with the real economy, the pseudonymity, decentralisation, and lack of a clear situs of blockchains pose entirely new challenges to tax compliance and transparency.
The author examines how current inter- and supranational frameworks — including the OECD's Crypto-Asset Reporting Framework (CARF), the EU's Directive on Administrative Cooperation (DAC), and the US Foreign Account Tax Compliance Act (FATCA) — apply to crypto assets. The book also addresses crypto asset users' rights as taxpayers involved in exchange of information procedures.
With regard to the substantial tax treatment of crypto assets and national procedures on exchange of information, Switzerland, Belgium, and the United States have been chosen as representative jurisdictions on the basis of their contrasting policies on crypto assets and their particular legal contexts.
First comprehensive academic analysis of crypto tax transparency through the lens of exchange of information. Detailed taxonomy of crypto assets and their service providers. Examination of the OECD's CARF and the EU's DAC in enabling automatic exchange of information (AEOI) on crypto assets. Analysis of FATCA and US Treasury regulations governing broker reporting on digital assets. Comparative study of the substantial tax treatment of crypto assets in Switzerland, Belgium, and the United States. Thorough treatment of the Global Forum's exchange of information on request (EOIR) standard. Assessment of taxpayer rights in the context of exchange of information procedures.
How pseudonymity, decentralisation, and lack of clear situs challenge tax transparency. Taxonomy of crypto assets and crypto asset service providers. Substantial tax treatment of crypto assets in selected jurisdictions. Relevant binding legal instruments and non-binding models on exchange of information. What information on crypto assets should be subject to exchange of information procedures. The roles of CARF and DAC in enabling AEOI on crypto assets. Potential role of FATCA and US Treasury regulations on digital asset broker reporting.
Thomas Dilen is a specialist in international tax law with a focus on the intersection of blockchain technology and tax transparency frameworks.
List of Abbreviations — Acknowledgements
PART I. Blockchain Technology, Crypto Assets and Direct Taxation
Chapter 1. Introduction
Chapter 2. Blockchains and Crypto Assets
Chapter 3. Crypto Assets' Substantial Taxation and Enforcement
PART II. Crypto Assets and Exchange of Information on Request
Chapter 4. International EOIR Standard
Chapter 5. Crypto Assets under the International EOIR Standard
PART III. Crypto Assets and Automatic Exchange of Information
Chapter 6. International AEOI Standard for Crypto Assets
Chapter 7. Specific Aspects of AEOI on Crypto Assets in the United States
PART IV. Concluding Remarks
Chapter 8. Crypto Tax Transparency Beyond Exchange of Information?
Chapter 9. Conclusion
Bibliography — Table of Treaties — Table of Legislation — Table of Cases — Index
This is the definitive reference for tax professionals, compliance officers, and legal advisors navigating the rapidly evolving regulatory landscape of crypto asset taxation. With governments worldwide implementing new reporting frameworks, this book provides the structured legal analysis needed to ensure compliance and understand the obligations of both crypto asset users and service providers.
Keywords: crypto tax transparency, CARF, crypto-asset reporting framework, exchange of information, AEOI, EOIR, FATCA, blockchain taxation, DAC8, crypto asset regulation, international tax law, digital asset reporting, cryptocurrency compliance, tax treaty, Global Forum
Target Audience: International tax lawyers, tax advisors, compliance officers, cryptocurrency exchanges, fintech companies, tax authorities, government regulators, academic researchers in tax law, law libraries, university libraries
Genre: International Tax Law, Blockchain and Cryptocurrency Law, Financial Regulation
Q: What is the OECD Crypto-Asset Reporting Framework (CARF) and how does it apply to crypto exchanges?
A: The OECD's CARF establishes a standardised framework requiring crypto asset service providers to collect and report information about their users' crypto transactions to tax authorities. This information is then exchanged automatically between participating jurisdictions. The framework aims to close the transparency gap that allowed crypto assets to bypass traditional financial reporting mechanisms. This book provides a comprehensive legal analysis of CARF's scope, requirements, and practical implementation challenges.
Q: How are crypto assets taxed differently in Switzerland, Belgium, and the United States?
A: These three jurisdictions represent contrasting approaches to crypto taxation. Switzerland generally treats crypto assets as movable property with wealth tax implications, Belgium applies a case-by-case assessment distinguishing between normal management of private assets and speculative activity, while the United States classifies crypto assets as property subject to capital gains tax with specific broker reporting obligations. This book analyses these frameworks comparatively within the context of international information exchange.
Q: What is the relationship between FATCA and crypto asset reporting in the United States?
A: FATCA was originally designed for traditional financial accounts but is increasingly relevant to crypto assets. The US Treasury has issued regulations governing broker reporting on digital assets that complement FATCA's reach. This book examines how FATCA's framework interacts with the new crypto-specific reporting requirements and the implications for foreign financial institutions holding crypto assets on behalf of US persons.
Q: How does the EU's DAC8 directive address automatic exchange of information on crypto assets?
A: The EU's eighth amendment to the Directive on Administrative Cooperation extends the scope of automatic exchange of information to cover crypto assets. It requires crypto asset service providers operating within the EU to report transactions to their national tax authorities, which then share this information with other EU member states. This book analyses DAC8's provisions alongside CARF to assess their combined effectiveness.
Q: What challenges does blockchain decentralisation pose for international tax transparency?
A: Blockchain's decentralised architecture creates fundamental challenges for tax authorities: there is no central intermediary to serve as a reporting entity, transactions are pseudonymous rather than anonymous, and crypto assets lack a clear geographic situs for jurisdictional purposes. This book examines how international standards attempt to address these challenges through service provider reporting obligations and enhanced exchange of information mechanisms.
Q: What rights do taxpayers have when their crypto asset information is exchanged between countries?
A: Taxpayers involved in cross-border exchange of information procedures relating to crypto assets retain fundamental rights including data protection, notification rights (where applicable), and the right to challenge the legality of information requests. However, the scope and enforcement of these rights vary significantly between jurisdictions and exchange mechanisms. This book provides a detailed analysis of taxpayer protections under both EOIR and AEOI frameworks.
Q: Is the Global Forum's EOIR standard still adequate for crypto assets?
A: This is one of the central questions addressed in this book. The author critically evaluates whether the Global Forum's exchange of information on request standard — designed for traditional financial information — can cope with the unique characteristics of crypto assets, including their pseudonymity and decentralisation. The analysis suggests that while EOIR remains a relevant tool, it faces significant limitations that CARF and DAC aim to address.
Q: Where can I buy Crypto Tax Transparency by Thomas Dilen with international shipping?
A: CLNZ Books offers Crypto Tax Transparency: Crypto Assets and Exchange of Information for Tax Purposes (Kluwer Law International, 2026) by Thomas Dilen with international shipping via international couriers included in the price. Orders are delivered to addresses worldwide, with no additional shipping charges at checkout.
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