13 November 2026 · Reglapp
A client offers to pay for your consultation in cryptocurrency. You agree, but then a question comes up: what amount should go on the invoice, and when do you recognise the income — when you receive the coins or when you withdraw the money to your bank account?
Payment for your work is still business income, even if the money has not reached your bank account. For tax purposes, you need its value in euros. You also need to record the crypto you receive and everything you do with it afterwards: selling or swapping it may create a separate gain or loss.
This article looks at payments received by an autónomo — a self-employed person working in Spain who is a Spanish tax resident and pays personal income tax under the general IRPF rules.
Contents
- How to invoice when you are paid in crypto
- What happens when you sell the crypto you received
- Can you claim a loss on the sale
- Do crypto-to-crypto swaps count
- How to calculate the result with several receipts (FIFO)
- What if the crypto stays in your wallet
- When Modelo 721 is required
- Which records to keep
- What your bank may ask for when you withdraw funds
- FAQ
- How to sort out your own payment
How do you invoice when you are paid in crypto?
For the work you have done, you issue the client an invoice — a factura. The easiest approach is to agree the price of the service in euros first, and then work out how much crypto the client needs to send to cover it.
If the consultation costs €350, that is the price that stays on the invoice. Any later rise or fall in the value of the coins you received does not change it. VAT (IVA) and IRPF withholding, where they apply, are shown according to the rules for your transaction. Choosing crypto as the means of payment does not in itself exempt the service from IVA, as confirmed by a binding ruling from the Spanish tax directorate (DGT).
If the fee was agreed as a specific number of coins, you will need a valuation in euros. Keep the contract terms, the transaction date, the amount of crypto and the source of the exchange rate. Your tax adviser will check which date and value to use for recognising the income.
Don’t tie the invoice to when you plan to withdraw the funds. The deadline for issuing it depends on the transaction itself and on the client’s status. For IRPF, the general rule is to recognise income when it accrues, regardless of when it is paid; some self-employed people may opt for cash-basis accounting instead. That is why a one-size-fits-all formula like “always invoice at the exchange rate on the payment date” doesn’t work in every case.
Sources: invoicing deadlines, general income recognition rule (accrual) and cash-basis accounting.
What happens when you sell the crypto you received?
If the crypto is held as a personal asset and you sell it outside your business activity, the difference between the sale value and the acquisition value is treated as a capital gain or loss — a ganancia or pérdida patrimonial. The result goes into your annual income tax return — the Renta, filed on Modelo 100.
If the crypto is used for business payments or your crypto transactions are linked to your activity, your tax adviser will determine the accounting treatment separately. The example below covers the sale of a personal asset.
Worked example: a €350 consultation
You provided a consultation for €350 and received crypto worth €350 on the same day. You hold no other coins of this type. To show only the change in value, the example leaves out IVA, IRPF withholding and fees.
How the service payment and the later sale of coins are recorded
What happened
How it is recorded
You provided the service and received €350 in crypto
€350 — business income
A month later, you sold all of that crypto for €380
€30 — a separate gain on the sale of the asset
Or you sold it for €300
€50 — a separate loss on the sale of the asset
You don’t need to change the invoice from €350 to €380 because of the coin sale. The extra €30 appeared after you were paid for the work, when the value of the asset changed.
The calculation also takes into account documented costs directly related to buying and selling. That is why your adviser needs the full transaction history with fees, not just the amount that reached your bank.
Source: AEAT rules on selling cryptocurrency.
Can you claim a loss on the sale?
Yes, a documented loss on the sale of a personal asset is reported in the Renta. But a €50 loss does not mean the tax office will refund you €50, or that you can simply deduct it from your consultation income.
These losses are subject to offset rules within the savings income category — the base del ahorro. Your adviser will check which income the loss can be offset against and whether any amount can be carried forward to future years.
If the price has fallen but you are still holding the coins, the drop in price alone is not a realised loss.
Source: IRPF Law (Ley del IRPF), Articles 33 and 49.
Do crypto-to-crypto swaps need to be reported?
Yes. For example, swapping bitcoin for USDT is a separate transaction that may result in a gain or loss. You don’t need to receive euros or withdraw money to your bank account for this to happen.
Keep the date of the swap, the number of coins given and received, their euro value and the fees. Special valuation rules apply to swaps: the higher of the market values of the asset given and the asset received is used.
Moving the same coins between your own wallets is not, in itself, a sale. Still, it is worth noting these transfers in your records so your adviser doesn’t mistake them for new receipts.
Source: AEAT guidance on swaps and calculating the result.
How do you calculate the result if you received crypto several times?
For identical coins, FIFO applies: the coins you acquired first are treated as the first ones sold.
For example, you received bitcoin in January and February, and sold some in March. The calculation starts with the value of the January receipt. If you already held bitcoin before these payments, that earlier acquisition must also be taken into account.
This rule also applies across different exchanges. So give your adviser the complete history for each type of cryptocurrency, including earlier purchases if those coins are still part of the calculation.
Source: FIFO method in AEAT guidance.
What if the crypto stays in your wallet?
You still need to account for the income from the work you did. Simply holding a personal asset — without selling, swapping or otherwise transferring it — does not usually create a separate taxable gain from an increase in its value.
Other obligations may still apply, however. Crypto counts towards wealth tax — the Impuesto sobre el Patrimonio — if you fall within its scope. For assets held with foreign custodians, you also need to check whether you must file Modelo 721.
Source: cryptocurrency and wealth tax.
When is Modelo 721 required?
Modelo 721 is an information return for cryptocurrency held abroad. Filing it does not, in itself, mean paying a separate tax.
The question of a first filing usually arises if, on 31 December, the total value of your crypto held with foreign custodians exceeds €50,000. The threshold is calculated across all holdings combined, not per exchange.
Who holds the private keys
It matters who holds the private keys. If only you control them and there is no third-party custodian, those coins are not included in Modelo 721. If your assets are held on a platform, you need to establish which legal entity services your account and where it is based.
There are also exemptions linked to keeping full accounts under the Spanish Commercial Code. A simple spreadsheet of transactions does not, on its own, qualify for this exemption.
Deadlines and subsequent filings
The filing period is from 1 January to 31 March of the following year. After the first return, whether you need to file again depends, among other things, on whether your total balance has increased by more than €20,000 compared with the last return filed, and on whether you have stopped holding previously declared assets. It is worth checking these circumstances with an adviser.
Sources: who files Modelo 721 and how custody is treated, threshold and exemptions, deadlines and subsequent filings.
Which records should you keep?
Start with a single spreadsheet that lets you trace every receipt and every later movement of coins.
For each transaction, record:
- the date and time;
- the type of transaction: payment for a service, purchase, sale, swap or transfer between your own wallets;
- the name and amount of the cryptocurrency;
- the euro value and the source of the exchange rate;
- the fee, including the currency it was charged in;
- the exchange or wallet and the transaction ID;
- the client invoice number, if it is a payment for work.
Add your invoices, contracts and full transaction exports from exchanges and wallets for the year. If you sold coins received earlier, you will need records of how you acquired them in previous periods.
With this information, your tax adviser (gestor) can link each payment to a specific service, verify the value of the asset and calculate the result of later transactions.
What might your bank ask for when you withdraw funds?
A Spanish bank may ask you to prove the source of funds. To be ready, keep the whole chain: the contract with the client, the invoice for the work, the receipt of the crypto, its sale, and the transfer of euros to your bank account.
If the information you provide is not enough, the bank may restrict your account. So it is best to prepare documents before withdrawing a large amount and to respond to the bank’s request within the deadline it sets. These checks stem from customer and transaction due-diligence requirements; they should not be put down solely to your nationality or a recent move.
If you sell crypto for cash, including through a crypto ATM, the way you receive the money does not remove the need to record the sale. Keep proof of the transaction and the fees.
Source: Banco de España on account checks and restrictions.
Frequently asked questions about crypto payments
Can an autónomo in Spain accept payment in cryptocurrency?
Yes, if you have agreed on this payment method with the client. For tax purposes, the value of the service must be determined in euros. A crypto payment is still business income and does not change the usual rules for invoicing and taxing the service.
Which exchange rate should I use on the invoice?
If the price of the service was agreed in euros, put that amount on the invoice. If the fee was set as a number of coins, you will need a euro valuation on the relevant date. That date depends on the terms of the transaction and the accounting rules: you cannot simply use the date you withdraw the funds.
Do I need to declare the income if the crypto has not yet been withdrawn to my bank account?
Yes. Income from work you have done is recognised under the rules that apply to you, regardless of whether you have withdrawn the funds. At the same time, simply holding crypto as a personal asset does not usually create separate taxable income from an increase in its value. Obligations relating to Modelo 721 and wealth tax are checked separately.
When I sell the crypto, will I be taxed again on the full amount?
When a personal asset is sold outside your business activity, what is calculated is the difference between the sale value and the acquisition value, taking into account documented costs directly related to the transactions. For example, with an acquisition value of €350 and a sale at €380, the gain before fees is €30. This result is reported in the Renta. For crypto used in the business, the accounting treatment is checked separately.
Do I need to declare a swap of bitcoin for USDT?
Yes, swapping one cryptocurrency for another can create a gain or loss even if you did not receive any euros. For transactions with personal assets, the result is reported in the annual Renta under the rules for swaps. Keep the number of coins, their euro value on the date of the swap, and the fees.
Can I reduce my tax if my crypto has dropped in value?
A price drop on its own is not enough. If a documented loss arises when you sell or swap a personal asset, it is taken into account in the Renta under the loss offset rules. It is not an automatic refund and does not directly reduce the income from the service you provided.
How does FIFO work if my crypto is held on different exchanges?
For the same type of cryptocurrency, the coins acquired first are treated as sold first. Different exchanges do not create separate FIFO queues. That is why your adviser needs the full history of purchases and sales, including transactions from previous years, if those coins are still part of the calculation.
If I hold less than €50,000 in crypto, can I skip declaring the income?
No. The €50,000 threshold relates to the conditions for filing the Modelo 721 information return for the first time, not to any tax exemption on income. Payments for services and the results of sales or swaps must be accounted for regardless of your balance. If you have already filed Modelo 721, whether you need to file again is checked separately.
When do I need to file Modelo 721?
For a Spanish tax resident, the obligation usually arises if, on 31 December, the total value of crypto held with foreign custodians exceeds €50,000. Coins in a wallet whose private keys only you control are not included in this return. The filing period is from 1 January to 31 March of the following year. There are exemptions and separate rules for subsequent filings.
What documents do I need for my records and to prove the source of funds?
Keep the contract and the client invoice, the history of crypto received, sold and swapped, the euro value of each transaction, the fees, and proof of the transfer to your bank account. For coins acquired earlier, you will need the history of how you obtained them. If you sold for cash or through a crypto ATM, you will also need supporting documents.
How to sort out your own crypto payment
If you are already being paid in crypto, start with one invoice and the history of the related transaction. Note what happened to the coins next: whether they stayed in your wallet, were sold or were swapped.
At Reglapp, you can discuss this kind of payment with a tax adviser in Russian. They will review your documents, explain how it should be accounted for and identify what information you need for your tax filings. A manager will help you organise the handover of documents and agree on the next step.
Request a consultation on the Reglapp website
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