In recent months, the topic of stablecoins has become central to the debate on cryptocurrency taxation in Italy. Not so much for their use as a payment tool or for stabilizing volatility, but rather for the fiscal distortions that some recent regulatory choices are causing.
During an Instagram live session, tax expert Stefano Capaccioli analyzed one of the most controversial aspects of the current regulation: the tax treatment of E-money tokens, particularly those denominated in euros, such as EURC, compared to dollar-pegged stablecoins, like USDC.
With the implementation of the MiCAR regulation, stablecoins are classified at the European level as E-money tokens when they represent a stable value pegged to a fiat currency. This context includes both euro and dollar stablecoins.
However, the Italian tax regulation introduces a significant distinction: the 26% tax rate is confirmed only for income and capital gains derived from E-money tokens denominated in euros. For all other crypto-assets, including dollar-denominated stablecoins, the more punitive regime remains, with a tax rate of 33% starting from 2026.
According to Capaccioli, this approach raises more than a few concerns. On one hand, it seems like an attempt to favor instruments pegged to the single currency. On the other hand, it ignores a fundamental fact: within the European Union, the euro is not the only currency.
Countries like Sweden, Denmark, and Hungary use different currencies, fully legitimate within the single market. Limiting the tax benefit exclusively to E-money tokens in euros could therefore come into conflict with the principle of free movement of capital, one of the pillars of the European framework.
The real short circuit, however, emerges in practice. As observed by Capaccioli, if a taxpayer realizes a capital gain on Bitcoin and converts the value into EURC, the capital gain is still taxed at 33%, because it originates from the original asset.
At the same time, the regulation establishes that the conversion of E-money tokens into euros does not generate capital gains. This leads to a curious outcome: the only scenario in which the 26% tax rate might apply concerns very limited cases, such as lending EURC in exchange for interest.
During the live session, another problematic aspect was highlighted. By combining the regulations on crypto-to-crypto swaps and those on E-money tokens, a preferential treatment could emerge for certain operations involving dollar stablecoins.
In theory, an exchange from USDC to EURC could fall under the swaps of crypto-assets “having the same characteristics and functions,” and therefore not be taxable. If subsequently, the EURC is converted into euros without generating a capital gain, it creates a regulatory gap that risks encouraging opportunistic behaviors.
The introduction of specific regulations for euro-denominated E-money tokens could have represented a step forward. However, as currently formulated, it risks increasing uncertainty and producing effects opposite to those desired.
As often happens with Italian crypto taxation, the issue is not the intention, but the execution: a layering of regulations that intersect without coordination, leaving taxpayers and professionals in a permanent gray area.
Amelia Tomasicchio
Editor in Chief and co-founder at The Cryptonomist
