The Contents of Intertax, Volume 54, Issue 3, 2026

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:

Not ‘Super Tax Havens’ After All

When crypto-assets were first introduced, tax experts worried that they might become ‘super tax havens’. With over a decade and a half of hindsight, this article questions whether this tax-enforcement doomsday scenario has materialized or may yet materialize. The article’s conclusion is that the answer is ‘no’. To be sure, crypto-assets are an instrument of tax evasion, but they are not better (and maybe even worse) at facilitating tax evasion than traditional tools such as cash or secrecy jurisdictions. With some adjustments, traditional, time-tested mechanisms of tax enforcement can address tax evasion with cryptocurrencies at least as effectively as addressing any other form of tax evasion. The reason for this is rather simple: contrary to initial hopes (or warnings, depending on one’s perspective), the crypto-assets markets are not disintermediated, not decentralized, and not anonymous, and they are unlikely to become any of those things. If governments chose not to enforce tax laws in the context of crypto-assets, this would be a policy choice, not an inevitability attributable to the nature of blockchain technology.

CARF’s Impact on the Crypto Marketplace: An Equal and Opposite Reaction?

In this article centred on the OECD’s Crypto-Asset Reporting Framework (CARF), a leading US tax practitioner based in Zurich shares his expectations on the fall-out from the incoming crypto asset reporting regimes. Grounding his views in precedents from recent tax reporting for conventional asset classes, he forecasts resistance from the industry and investors, leading to novel enforcement challenges faced by tax authorities when confronted by an agile and motivated target. In closing, he sets out a series of enhanced enforcement proposals that tax authorities might adopt to further CARF compliance.

Exchange of Crypto Information in the ‘Pre-AEOI Phase’: Can Non-CARF Countries Use Group Requests to Obtain Information from Foreign CASPs?

The article examines the use of ‘group requests’ by countries to obtain information on crypto assets held by their residents through foreign Crypto Asset Service Providers (CASPs). With information exchanged under the OECD’s Crypto Asset Reporting Framework (CARF) set to commence in 2027, many Global South nations remain uncommitted due to administrative constraint. Many of these countries host significant domestic crypto markets. The author proposes that group requests can serve as a powerful alternative to ‘mimic’ the compliance effects of automatic exchange of information (AEOI) under the CARF. The study outlines a practical methodology for executing these requests. It begins by identifying how countries can overcome the lack of comprehensive macroeconomic data on cross border crypto activities. Countries can use the methodology developed by the Financial Action Task Force (FATF) methodology to identify relevant CASP jurisdictions. It then details the conditions for validity under the OECD’s ‘foreseeable relevance’ standard, ensuring requests are not dismissed as illegal ‘fishing expeditions’. Finally, the article analyses the legal viability of basing such requests on bilateral tax treaties, tax information exchange agreements (TIEAs), and the Multilateral Convention (MAAC). The article concludes by providing a checklist for a successful use by tax authorities of crypto group requests.

Sixteen Years of Bitcoin: Resolved and Unresolved Issues in the Taxation of Crypto Assets

Bitcoin’s sixteenth anniversary in 2025 provides an important juncture to reflect on how tax law has responded to the emergence of crypto assets. Initially hailed as ‘the monetary experiment of our time’, Bitcoin and its successors have challenged fundamental tax concepts and exposed divergences in domestic and international tax systems. This article first revisits the debate on whether crypto assets should be characterized as ‘money’, demonstrating that classification matters only to the extent that tax consequences diverge across regimes. It then examines four unresolved issues that continue to occupy scholars and policymakers: the characterization of mining rewards as entrepreneurial income or windfall gains; the treatment of staking rewards as active or passive income; the tax consequences of blockchain hard forks; and the classification of collateral use of crypto assets in decentralized finance. Each issue reveals tensions between traditional tax analogies and the novel features of blockchain-based activities, highlighting trade-offs between theoretical purity and administrability. While global convergence is unlikely due to foundational differences in tax systems, the analysis underscores the importance of clarity, consistency, and functional approaches to ensure that taxation keeps pace with technological innovation.

Cryptoasset Taxation and Accounting: Aligning Standards for Cross-Border Clarity and Compliance

This article examines how accounting standards shape the taxation of cryptoassets, focusing on key differences under the International Financial Reporting Standards (IFRS), US Generally Accepted Accounting Principles (US GAAP), and selected offshore jurisdictions. Fragmented accounting and tax frameworks create substantial obstacles to cross-border compliance despite their growing economic significance. The article draws on a comparative regulatory analysis and corporate case studies (MicroStrategy, Coinbase, and Tesla) and identifies three persistent frictions at the book-tax interface. First, classification friction arises because jurisdictions treat the same asset as intangible property, a financial instrument, or a commodity thereby creating uncertainty for fiat-backed stablecoins and security-like tokens. Second, timing friction stems from mismatches between accrual-based financial reporting and realization-based tax rules especially for staking rewards, crypto lending, decentralized finance (DeFi), and derivatives. Third, valuation friction reflects tension between historical cost and fair value compounded by volatility and fragmented liquidity which disproportionately affects complex instruments and international structures. The article proposes the tax-accounting alignment framework (TAAF) as a conceptual roadmap to address these challenges. It prioritizes economic substance over legal form using functional classification, blockchain finality as an objective recognition trigger and adaptive valuation thresholds. The framework illustrates how these principles can simplify compliance and enhance tax transparency in cross-border and arbitrage-sensitive settings.