What is a crypto intermediary?
A crypto intermediary is a platform that manages or holds your cryptocurrencies on your behalf. Common examples include centralized exchanges (like Binance, Coinbase, Crypto.com) and custodial wallets (wallets where you don't directly control your private keys, but a third party manages them).
Non-custodial wallets (where only you have access to your private keys, like MetaMask or Ledger) are not considered intermediaries: in these cases, no third party manages your funds.
Why is it important to specify the intermediary's nationality?
In some countries, the intermediary's nationality (i.e., whether the platform is resident in your country of fiscal residence or abroad) is crucial for crypto tax reporting. If your crypto is managed by a foreign intermediary, you might need to fill out specific forms or follow different rules for declaring transactions, income, or capital gains.
In which countries is it mandatory to select the intermediary's nationality?
Currently, selecting the intermediary's nationality is required when adding an exchange connection in the following countries:
Spain
Portugal
If your tax residency is outside of the countries listed above, this article does not apply to you.
Spain
Why do you need to select the nationality in Spain?
In Spain, if you hold more than €50,000 of crypto with foreign intermediaries, you are required to fill out Form 721 for foreign assets. To check if you exceed this threshold and to generate the prefilled 721 form, we need to know the nationality of your connections.
How to check an intermediary's nationality in Spain?
An intermediary is considered Spanish if it:
has a legal seat or a permanent establishment in Spain; and
is registered with the Bank of Spain as a virtual asset service provider (VASP).
Attention: If it does not meet both requirements, it should be considered foreign, even if it offers services in Spanish or allows access from Spain.
You can check if a crypto asset intermediary is registered with the Bank of Spain at this link
Portugal
Why do you need to select the nationality in Portugal?
In Portugal, the intermediary's nationality determines which tax annexes and forms (IRS) must be completed and how capital gains, income from staking, lending, airdrops, etc., should be declared. A foreign intermediary may entail additional reporting and documentation obligations, as well as possible differences in tax treatment.
How to check an intermediary's nationality in Portugal?
An intermediary is considered Portuguese if it:
has its legal seat in Portugal;
holds a Portuguese Tax Identification Number (NIF);
is registered and authorized by the Bank of Portugal as a virtual asset operator.
Attention: if even one of these requirements is not met, the intermediary should be considered foreign.
You can find the list of crypto asset intermediaries registered with the Bank of Portugal at this link