Buying Crypto in Belgium: On-Chain, via an Exchange or via a Bank (Bolero) – Does It Make a Tax Difference??

Buying Crypto in Belgium: On-Chain, via an Exchange or via a Bank (Bolero) – Does It Make a Tax Difference?

On 16 February 2026, Bolero became the first Belgian bank to launch a platform allowing retail investors to invest directly in crypto-assets, currently limited to bitcoin (BTC) and ether (ETH). This launch fits within a broader European trend: crypto is increasingly being offered through traditional banks and within a clearer regulatory and supervisory framework.

Following this launch, several clients asked us whether the way in which crypto is acquired, on-chain, through a foreign exchange, or through a Belgian bank such as Bolero, has any impact on the Belgian tax treatment upon disposal.

We can be clear from the outset: the method of acquisition as such does not change the tax qualification of the capital gain. Belgian tax rules essentially look at the nature of the transaction and the manner in which the assets are managed, not at the platform through which the crypto was purchased.

That being said, the chosen acquisition method can have other tax-related and practical implications. We set these out below in a structured way.

Four ways to buy crypto today

In practice, crypto can broadly be purchased in four different ways. We intentionally focus on the main lines below, without aiming to be exhaustive.

1. Buying via a crypto exchange (Kraken, Bitvavo, Coinbase, Binance, …)

This is currently the most common and best-known method. The investor opens an account with a trading platform and buys or sells crypto-assets there. It is important to stress that these platforms are generally not banks in the traditional sense of the term.

In most cases, this involves a custodial exchange. This means the investor does not manage their private keys themselves. The exchange holds the crypto-assets on behalf of the customer, meaning the customer does not have direct control over the underlying private keys and, therefore, over the crypto itself. This is practical and user-friendly, but it also implies that custody depends on a third party.

From a Belgian tax perspective, the key point is that many, and currently in practice all, of these exchanges are established abroad. In that case, the account must in principle be reported to the Central Point of Contact (CAP) of the National Bank of Belgium, and its existence must also be disclosed in the annual Belgian personal income tax return. Failure to comply with these reporting obligations may lead to administrative penalties.

The tax treatment of a later sale is not determined by the fact that the acquisition was made through a foreign exchange, but rather by the nature of the investor’s conduct: normal private asset management, speculative behaviour, or professional activity.

2. Buying and selling on-chain through a personal wallet (self-custody)

A second option is buying and selling crypto directly through a personal wallet, where the investor manages their private keys themselves. This can be done without using a centralised exchange, for example via a hardware wallet or a non-custodial wallet combined with a decentralised exchange (DEX). A commonly used example is MetaMask.

In this scenario, the investor fully controls their crypto. There is no central counterparty holding the assets. The advantage is maximum control. The downside is that the investor is also fully responsible. Loss of private keys, transaction mistakes, or interactions with fraudulent smart contracts are in principle irreversible.

From a tax perspective, this does not change the qualification of any later capital gain. Here too, the Belgian tax authorities will assess whether the investor’s behaviour qualifies as normal private asset management or rather as speculative or professional activity.

As regards reporting obligations, a pure self-custody wallet without any foreign intermediary does not, in principle, qualify as a foreign account that must be reported to the CAP. However, once a foreign exchange or intermediary is used, the reporting obligation may arise again.

3. Buying through a Belgian bank (such as Bolero)

Since 16 February 2026, it has been possible to invest directly in BTC and ETH via Bolero. This is an important step: for the first time, a Belgian bank provides direct access to crypto-assets within the traditional banking framework.

Because Bolero is a Belgian financial institution, there is no CAP reporting obligation. Only foreign accounts must be reported. Likewise, there is no separate requirement in the Belgian personal income tax return to disclose the existence of a Belgian securities account or crypto account.

From a substantive tax perspective, however, this does not change the treatment of capital gains. As already mentioned, the method of acquisition does not determine whether a capital gain is taxable.

How does Bolero crypto work technically?

Bolero operates a closed model where customers can only buy and sell within the Bolero platform itself. In practice, this means that no transfers are possible to or from external wallets, other exchanges or on-chain protocols. For example, it is not possible to transfer BTC from Kraken to Bolero.

The crypto-assets are held in custody within the bank’s infrastructure. As with a crypto exchange, this relieves the customer from managing private keys, but it also means the customer loses direct control over the coins. For some investors this is an advantage, as it reduces the risk of loss due to mistakes or phishing. For others it is a drawback, because within the crypto world the well-known adage applies: “not your keys, not your coins”.

Onboarding and knowledge and experience test

Before customers can start investing in crypto through Bolero, they must complete a mandatory knowledge and experience test. Bolero continues to operate under an execution-only model: customers make their own investment decisions and do not receive investment advice, but they are informed about the risks and characteristics of crypto-assets.

4. Peer-to-peer transactions (P2P)

A fourth option is the direct purchase or sale between individuals or companies, without using an exchange, bank, or even a wallet platform such as MetaMask. This often takes place entirely outside any structured platform.

Here too, the tax treatment of a later capital gain does not depend on the fact that the transaction was peer-to-peer. However, evidentiary issues arise more easily, for example regarding the purchase price, transaction date and the identity of the counterparty. In practice, this is also the method where the risk of disputes with banks or the tax authorities may be highest, precisely because documentation is often more limited.

Exchange, on-chain or bank: what changes from a tax perspective?

As indicated in the introduction, it generally does not matter where or how the crypto was acquired.

Under the Belgian tax framework applicable up to and including 2025, a capital gain on crypto could be tax-free if it fell within the scope of normal private asset management. If there is speculation or abnormal asset management, the gain is in principle taxed as miscellaneous income at 33% (plus municipal surcharges). If the activity is deemed professional, progressive personal income tax rates may apply.

In the public debate, it is widely assumed that a new general capital gains tax on financial assets, including crypto-assets, will be introduced in 2026. The precise content, timing and modalities of such a reform remain dependent on legislative decisions. It is therefore important to remain cautious with overly definitive statements until the final rules have been adopted.

In any event, the key element remains the qualification of the investor’s behaviour, not the acquisition channel.

Does the acquisition method really have no tax relevance?

In principle, no. Belgian tax law does not make a distinction based on whether crypto was acquired via an exchange, on-chain or through a Belgian bank.

That said, it cannot be fully excluded that the Belgian tax authorities, when assessing whether an investor acted as a prudent private investor, may also take factual elements into account. It is conceivable that investing through a regulated Belgian bank may be perceived as more cautious or “classic” than intensive trading through decentralised protocols or anonymous peer-to-peer transactions.

Whether such reasoning would stand up legally is another matter. The mere use of a particular platform cannot, by itself, be decisive. But in discussions about speculative behaviour, the overall context of the investor is often considered.

Practical differences: repatriating funds

Where the choice of platform can make a difference is in practice when repatriating funds to a Belgian bank account.

In cases where crypto was held on-chain or traded through foreign exchanges, we regularly see Belgian banks ask additional questions when large amounts are transferred back. This may lead to delays or even temporary blocks under anti-money laundering obligations.

When the investment is made from the start through a Belgian bank such as Bolero, the investor remains within the traditional banking system. In that case, the sale and crediting of the proceeds can generally be expected to proceed in the same way as the sale of shares or other financial instruments.

This is not a tax argument, but it is a practically relevant factor.

Security and fraud risk

In practice, we still see numerous fraud cases involving crypto investments, often through fraudulent foreign platforms or fake advisers.

A regulated banking environment generally provides more oversight and consumer protection than an arbitrary foreign website. That does not change the market risk: crypto volatility does not disappear simply because the investment is made through a bank.

The question is whether the threshold to invest in crypto is becoming too low. Crypto-assets are technically and economically complex products. The classic adage that one should only invest in what one understands remains fully applicable.

Cost structure and limitations

Anyone considering investing via Bolero should take the cost structure into account. In practice, transaction costs are often higher than those charged by certain international crypto exchanges or on-chain purchases. For substantial volumes or frequent transactions, this cost aspect can weigh heavily.

In addition, the current offering is limited to BTC and ETH. For investors looking to diversify into smaller tokens or participate in DeFi applications, this is not a solution.

At first glance, staking does not appear to be possible with these coins, which constitutes a significant limitation.

Moreover, within the crypto community the principle “not your keys, not your coins” often applies. Those who want absolute control over their private keys will be less likely to choose a custodial bank solution.

Tax reporting, opt-in and opt-out, and documentation

A key practical difference between a bank platform and a classic crypto exchange is the availability of clear documentation. With foreign exchanges, we often see investors having to reconstruct their full transaction history themselves. With a Belgian bank, one can generally expect clear statements and transaction overviews aligned with Belgian reporting requirements, making it easier to evidence purchase prices, sale prices and timing in the event of a tax audit.

Following the introduction of the new capital gains tax, Belgian intermediaries will in principle be able to withhold this tax automatically through withholding at source. This system operates by default via opt-in: the tax is withheld upon sale by the bank unless the investor explicitly chooses opt-out. Those who opt out remain responsible for reporting the gains in their personal income tax return.

Even under opt-in withholding, it remains important to stress that the investor remains responsible for correct tax processing, notably to ensure exemptions or loss offsets are applied correctly.

By investing through Bolero in this way, investors can to a large extent ensure that their tax formalities are handled correctly. It should however be emphasised that withholding at source will typically be applied without automatically taking into account the annual exemption, for example EUR 10,000, and without full visibility on the investor’s overall annual result. There is also a timing difference: under withholding, the tax is deducted at the moment of sale, whereas under a standard tax return the final settlement only follows through the tax assessment notice.

Finally, it is only at the end of the tax year that it becomes clear whether there is an effectively taxable net gain, since a limited offset against loss-making trades may in principle be possible.

Estate planning: what happens upon death?

A frequently overlooked aspect of crypto investments is what happens upon the investor’s death.

With self-custody wallets, where the investor controls the private keys, practical problems often arise. Without access to the seed phrase or private keys, heirs may have a legal right to the crypto but may be unable to access it in practice. In such situations, the assets are effectively lost.

With crypto held through a regulated financial institution, the process is generally simpler. Heirs can, after presenting a certificate of inheritance, access the account and the assets through the same procedures that apply to securities accounts.

With foreign crypto exchanges such as Kraken or Binance, it is of course also possible for heirs to request access to the funds. In practice, however, this often involves significantly more paperwork and formalities: extensive documentation is typically required, additional evidence must be provided, and the procedure is not aligned with the Belgian inheritance system.

With a Belgian bank, by contrast, one can reasonably expect the process to be relatively smooth, much like the settlement of a traditional share portfolio, through the usual banking and notarial procedures.

In any event, crypto remains part of the estate. Inheritance tax is due according to regional rules. Valuation is in principle based on the market value at the date of death.

Does Belgian stock exchange tax (TOB) apply?

The Belgian stock exchange tax (TOB) is, as a rule, not applicable to the purchase or sale of crypto-assets, even where they are acquired through a Belgian bank such as Bolero.

Crypto-assets do not qualify as securities within the meaning of the TOB rules. The involvement of a bank does not change this legal qualification.

Conclusion

The way in which crypto is acquired, through a foreign exchange, on-chain, peer-to-peer, or through a Belgian bank such as Bolero, does not in principle affect the Belgian tax qualification of a later capital gain. The decisive factor remains whether the transaction falls within normal private asset management or whether it is speculative or professional in nature.

That does not mean the choice of platform is irrelevant. CAP reporting obligations, practical issues when repatriating funds, cost structure, security, documentation and estate planning are factors that do differ depending on the channel used.

Whether investing through a Belgian bank is “better” depends on the investor’s profile, knowledge and objectives. There is no purely decisive tax reason. But simplicity, comfort and institutional safeguards can be important for many investors.

FAQ – Buying Crypto and Belgian Tax

Does it make a tax difference whether I buy crypto via Bolero or via Binance?

No. The Belgian tax treatment of a capital gain depends on the nature of your investment behaviour, normal private asset management, speculation or professional activity, not on the platform.

Will crypto capital gains soon be taxed automatically?

From 2026, a general capital gains tax is expected to be introduced, and it will also cover crypto. This means that realised capital gains will in principle become taxable.

However, withholding will only be automatic if you invest through a Belgian intermediary such as Bolero and you keep the default option, opt-in. With foreign exchanges or on-chain transactions, there is no automatic Belgian withholding and you remain responsible for reporting and paying the tax.

Do I have to report a foreign crypto exchange account to the CAP?

In principle, yes, if it qualifies as a foreign account under the Belgian reporting rules. Its existence must also be disclosed in the Belgian personal income tax return.

Do I have to report a Bolero crypto account to the CAP?

No. Bolero is a Belgian institution. Only foreign accounts must be reported.

Can I transfer crypto I bought elsewhere, for example via Binance or on-chain, to Bolero?

No. Bolero does not allow inbound transfers from external wallets or foreign exchanges.

Does Belgian stock exchange tax (TOB) apply to crypto bought via Bolero?

As a rule, no. Crypto-assets do not qualify as securities for TOB purposes.

Will Bolero provide tax documents automatically?

One can generally expect a Belgian bank to provide clear transaction statements and overviews. This helps for evidence and calculations, but it does not remove the investor’s responsibility to file a correct tax return if needed.

What happens if I choose opt-in with Bolero, the default option?

Under opt-in, the capital gains tax will be withheld automatically by Bolero at the moment of sale. This is one of the key practical differences compared to foreign exchanges and on-chain transactions, where investors generally need to handle reporting themselves.

What if I choose opt-out?

If you opt out, no automatic withholding is applied. In that case, you remain responsible for reporting and settling the tax through your personal income tax return.

Will withholding automatically take into account an annual exemption, for example EUR 10,000?

In practice, withholding can be expected to be applied without automatically taking the annual exemption into account.

When do I know whether I have actually made a taxable net profit?

This is only fully clear at the end of the tax year, since gains and losses during the year may, to a limited extent, be assessed together.

Why do some investors still choose self-custody?

Because they want full control over their private keys and do not want to rely on a third party. This requires more technical knowledge and responsibility.

What happens to my crypto upon death?

With self-custody, this can be problematic if no one has access to the private keys. With a Belgian bank, it is generally simpler, as heirs can access the account through standard procedures. With foreign exchanges it is also possible, but in practice often more burdensome and less aligned with the Belgian inheritance system.