The Netherlands has opened a debate over whether self-custodied Bitcoin should be taxed differently from exchange-traded crypto products, while U.S. fair-value accounting rules are already changing how corporate treasuries report Bitcoin and Ethereum.
On September 29, 2026, the Dutch government sent parliament a proposal signed by Prime Minister Rob Jetten, Finance Minister Eelco Heinen and State Secretary Eerenberg. The plan would tax gains on financial instruments only at the moment of sale starting in 2028, abandoning most of an earlier plan to tax investors annually on value changes. Shares, bonds and options are named as examples, but Bitcoin is not mentioned anywhere in the letter, leaving a critical definition to the amending bill, or novelle.
For Dutch investors, the distinction matters. A Bitcoin ETF is a security and would likely fall under “all financial instruments,” moving to sale-based taxation in 2028. A coin held in a private wallet could remain classified as an “other asset,” subject to annual taxation on value changes through 2029 and moving to a realization basis only in 2030. The cabinet estimates about 90% of Box 3 assets that change in value would fall under realization-based taxation from 2028, while the remaining 10% would stay under annual value-change taxation until 2030.
Under current Dutch rules, crypto is already a Box 3 asset. The Belastingdienst requires taxpayers to declare Bitcoin and other cryptocurrencies at the exchange price at 00:00 on January 1, regardless of where the coins are held. For 2026, the assumed return on crypto is 6% and the Box 3 rate is 36%, equal to about 2.16% of taxable crypto wealth before allowances. Taxpayers may instead report a lower actual return, and unrealized gains already count in that calculation. The assumed return for other assets is set to rise in 2027 by 1.5 percentage points, which tax specialists calculate takes it from 6.37% to 7.87%.
If Bitcoin is not defined as a financial instrument, an investor holding €100,000 in a private wallet could face tax on a €100,000 paper gain if the price doubles, even if nothing is sold. A holder of a Bitcoin ETF in the same situation would owe nothing until sale. The proposal also includes revenue offsets: the tax-free wealth threshold drops to €30,846 in 2027, and the tax-free return is cut from €1,800 to €1,000. Government estimates show annual revenue losses from the shift of roughly €3.018 billion in 2028, €3.108 billion in 2029, €2.399 billion in 2030 and €1.960 billion in 2031.
Meanwhile, in the United States, FASB Accounting Standards Update 2023-08 has replaced the old impairment-only model for corporate crypto holdings. Under the previous rules, crypto was an indefinite-lived intangible asset carried at historical cost minus impairments, meaning companies could write down losses but could never write prices back up. The new standard, effective for fiscal years beginning after December 15, 2024, requires fair value measurement each reporting period, with both unrealized gains and losses recognized directly in net income. The scope covers assets that are intangible under GAAP, reside on a blockchain, use cryptographic security and are fungible; it includes Bitcoin and Ethereum but excludes NFTs, stablecoins and wrapped tokens.
The IRS still classifies virtual currency as property under Notice 2014-21, so every corporate sale, exchange or token swap is a taxable event. Corporations report crypto gains and losses on Schedule D of Form 1120 and may use FIFO, LIFO or specific identification. Starting in 2025, centralized and custodial crypto brokers must issue Form 1099-DA for covered transactions. The SEC also removed a major custody obstacle in January 2025 by rescinding Staff Accounting Bulletin 121 and issuing SAB 122, ending the requirement to record safeguarding liabilities for client digital assets.
Corporate adoption data shows the scale of the shift. Strategy, formerly MicroStrategy, held 528,185 Bitcoin in its first fair-value quarter ending March 2025, with a cost basis of $35.6 billion and fair value of $43.5 billion; by late September 2026 its holdings had grown to approximately 847,666 BTC. Tesla held 11,509 Bitcoin worth about $951 million at the end of March 2025, while Block held 8,997.89 BTC with a fair value of roughly $664 million. Steve Gallucci, global leader of the Deloitte CFO Program, said crypto remains a unique asset class and that the accounting treatment for digital assets appears to be a work in progress. A Deloitte survey from July 2025 found that 99% of surveyed CFOs expect crypto to become part of their business operations, though volatility, accounting complexity and regulatory gaps remain top concerns.
The combination of a pending Dutch tax definition and U.S. fair-value accounting means corporate and individual Bitcoin and Ethereum holders face a more complex but gradually clearer reporting environment. Until the Dutch novelle is published, however, self-custodied Bitcoin and regulated Bitcoin ETFs may remain on different tax calendars.
