Staking & Lending Crypto in Belgium: Normal Management of Private Wealth

📅 Last updated: 19 May 2026
· 🏷 Topic: staking rewards, crypto lending, normal management, miscellaneous income 33%, capital gains tax 10%
· 🇧🇪 For: Belgian individuals staking or lending crypto via a platform or DeFi

⚠️ Warning — high-risk product. Cryptocurrencies are particularly volatile. You may lose more than your initial investment.

The FSMA has published public warnings on financial fraud and high-risk products, including cryptocurrencies.

Never invest money you cannot afford to lose entirely.

More and more Belgian individuals are staking their cryptocurrencies or lending them via an exchange or DeFi platform. The reason is obvious: you keep your position and earn a return at the same time. But what does the Belgian tax authority say about those returns? Do you automatically fall under the 33% rate because you are actively doing something with your crypto?

The confusion is understandable. In the media, “staking” and “33%” often appear side by side, as if staking immediately pushes you into the speculative corner. That is not correct. There are two separate tax questions to distinguish: one about the return you receive (staking rewards, lending interest), and one about the potential gain if you sell your crypto later. Both questions have a different answer.

This article explains both questions for assessment year (AY) 2026 and 2027 (income years 2025 and 2026). The focus is on what counts for a Belgian individual holding crypto as a private investment — not as a professional activity.

Table of Contents

1. Two separate tax questions

When you stake or lend crypto, those activities generate two types of tax events:

Type of income	Nature	Tax rate
Staking rewards, lending interest	Return on your capital	30% movable income
Capital gain on sale	Profit on price appreciation	10% (normal management) or 33% (speculative)

Question 1 — the return: Are your staking rewards or lending interest taxed as movable income (30%), as miscellaneous income (33%), or are they exempt?

Question 2 — the capital gain: If you later sell your staked or lent crypto at a profit, do you fall under normal management (10% capital gains tax) or miscellaneous income (33% speculative)?

The answers to those two questions are independent of each other. Staking rewards are always treated separately from any profit you later make on the sale of your cryptocurrencies.

2. Staking rewards and lending interest: 30% movable income

The DVB (Advance Tax Ruling Service) (source in Dutch),
has taken a clear position in recent rulings (including VB 6 December 2022, no. 2022.0911 and VB 18 March 2025, no. 2025.0061):

staking rewards are in practice generally qualified as movable income on the basis of article 17, § 1 of the ITC92 (Income Tax Code 1992), in combination with the interest category of art. 19, 1° ITC92 (accessed 2026-05-19). Concretely, this concerns

compensation for the use of capital — comparable to interest on a savings account.

This has one direct consequence: the rate is 30%, not 33%. Staking rewards are also not exempt under “normal management”; that exemption principle applies only to capital gains on the underlying cryptocurrencies themselves, not to the returns you derive from them.

The same applies to crypto lending. If you lend cryptocurrencies or stablecoins via a platform and receive interest on them, that interest is also movable income at 30%. The amount of the loan itself is fiscally neutral; only the received interest is taxable.

When is the return taxable?

The taxable value is established at the moment of receipt, not at the moment of sale. If you receive a staking reward of 0.05 ETH on 15 March 2026, the ETH rate on that day applies. If ETH rises sharply afterwards, that additional appreciation is a capital gain — and that does fall under the capital gains regime (see section 5).

Off-chain vs on-chain staking

The DVB emphasises that qualification happens in concreto: the specific terms of the staking arrangement play a role.

Off-chain staking (via an exchange such as Coinbase or Binance Earn): the exchange stakes on your behalf and pays you a percentage. This closely resembles a savings or term account.
There is a strong likelihood the DVB qualifies this as interest (art. 17 §1 in conjunction with art. 19, 1° ITC92) → 30%.

On-chain staking has two sub-scenarios:
Passive delegation (you delegate your crypto to a validator node via your own wallet, without running the node yourself): most practitioner sources qualify this as ‘income from the use of movable assets’ (art. 17 §1, 3° ITC92), with an optional flat-rate cost deduction of 15%. Rate: 30% movable income.
Active validation (you run your own validator node, with technical uptime requirements and possibly multiple protocols): here the DVB considers it possible that the activity element outweighs passive capital management — then art. 90 ITC92 (33% miscellaneous income) or even professional income comes into view.

Note: liquid staking (e.g. stETH via Lido) and restaking protocols (e.g. EigenLayer) do not always fit neatly into the above three categories. When in doubt, a ruling via the DVB is advisable (see checklist).

For most private investors, off-chain staking via a platform applies. There, 30% movable income is the most likely qualification.

Figure 1 — Tax rate on your crypto returns (2026, private investor)

3. When does 33% apply? The normal-management test

The 33% in the title of this article refers to article 90, first paragraph, 1° of the ITC92 (accessed 2026-05-19). That article taxes profits or gains arising from incidental or speculative transactions as miscellaneous income at 33% (+ municipal surcharge). It is the rate that applies when the tax authority rules that your conduct falls outside the normal management of private wealth.

The central question: is your crypto activity that of a prudent investor managing their wealth for the long term, or does it look more like speculation?

The criteria applied by the DVB

The DVB uses an extensive questionnaire — revised in 2026 following the new capital gains tax — to form this assessment. The main factors are:

Portfolio share: since the 2026 revision of the questionnaire, the DVB applies a practical threshold of a maximum of 25% of your financial assets (savings + equities + bonds, not real estate) in cryptocurrencies. Exceeding that threshold makes a 33% qualification a real risk. Note: this threshold is a practical guideline of the DVB, not a statutory limit, and is not binding on the courts.

Transaction frequency: few transactions (indicatively: 1 to 3 per month) points to normal management. Daily or automated trading points to speculation.
Holding period: a multi-year horizon (2 to 3 years) fits normal management. Short rotation cycles — buying and quickly selling — are suspect.
Own funds: normal management means investing with your own money, not with borrowed capital. Anyone buying crypto on credit immediately has a risk profile the DVB considers abnormal.
Intent: was the investment intended as long-term wealth building, or specifically as a speculative transaction?
Professional background: do you have an IT or financial background? Then the DVB sets the bar higher.

It is the combination of all these factors — not any single criterion — that determines whether you are assessed as normal or speculative.

4. Does staking void your normal-management status?

This is the question that concerns many investors: does the fact that I stake or lend crypto automatically make me “speculative”?

The answer is no — staking and lending in themselves do not disqualify you from normal management. The capital gain you one day make on the staked crypto can still be taxed at 10% if the rest of your profile demonstrates normal management.

But there are scenarios where staking or lending does weaken your position:

You put more than 25% of your financial wealth into crypto that you stake: you exceed the threshold, which is a signal to the DVB.
You borrow money to buy crypto and then stake it: use of borrowed capital is a red flag for speculative behaviour.
You continuously reinvest staking rewards in an automated manner: if a DeFi strategy automatically reinvests rewards daily across multiple protocols, the frequency and complexity can be seen as “active trading”.
DeFi yield farming with high risk: providing liquidity to an AMM (automated market maker) combined with frequent rebalancing and impermanent loss strategies pulls your profile towards abnormal management.

Practical rule of thumb

Passive staking (you click “stake” on your exchange once a month) of a limited portion of your wealth, funded with your own money, fits the normal management profile. Active DeFi strategies with automatic reinvestment and borrowed capital are closer to speculative or even professional.

5. The 10% capital gains tax and staked crypto

The Law of 6 April 2026 (Belgian Official Gazette (BS) 21 April 2026, accessed 2026-05-19) introduced the capital gains tax on financial assets, including cryptocurrencies, for individuals acting within normal management of their private wealth. Key points:

Rate: 10% on net capital gains (art. 90, first paragraph, 9°, c ITC92 — inserted by the Law of 6 April 2026). No municipal surcharge.

Annual exemption: €10,000 per taxpayer (indexed). Those who do not fully use their annual exemption may carry forward up to €1,000 per year of the unused portion to the following year, for a maximum of 5 years — resulting in a maximum cumulative carry-forward of €5,000, and thus a ceiling of €15,000.

Calculation basis: FIFO method. The acquisition cost of your cryptocurrencies is calculated using first-in-first-out.

Snapshot value 31 December 2025: the market value of your cryptocurrencies on 31 December 2025 serves as the standard acquisition value for the calculation of capital gains from 1 January 2026. The taxpayer may, during a transitional period (expiry date depending on an FPS Finance circular), invoke the actual historical purchase cost if that is higher. Gains accrued before 2026 are exempt from the 10%.

Losses: deductible against gains in the same tax year.

How do you calculate the capital gain on staked crypto?

Suppose: you buy 1 ETH on 15 January 2026 for €3,000 (after the snapshot value reference date 31/12/2025; no step-up basis applies) and immediately stake that ETH. On 10 June 2026 you sell that 1 ETH for €3,800.

Acquisition value: €3,000 (actual purchase price on 15/01/2026).
Sale proceeds: €3,800.
Net capital gain: €800 → below the annual exemption of €10,000 for normal management; in this example effectively taxed at 0%.

Had you held the ETH before 31 December 2025, the snapshot value of 31 December 2025 (the market value on that date) would have been the fiscal acquisition basis, not the price at which you originally bought.

The staking rewards you have received in the meantime (e.g. 0.02 ETH on 15 February 2026) are taxed separately as movable income at the moment of receipt. Those received rewards form a new FIFO position at their value on the date of receipt.

Note: as of 2026-05-19, FPS Finance has not yet published a specific circular on how FIFO interacts with individual staking-reward inflows (separate FIFO pool per receipt or pooled). The method described here (rewards as a new FIFO position at receipt value) is the prevailing practitioner interpretation but is subject to future administrative clarification.

6. CAP, DAC8 and reporting obligations

Transparency is the other major change of 2026. Two mechanisms are relevant for investors who stake or lend via platforms:

Central Point of Contact (CAP)

Accounts held at custodial exchanges (platforms that manage the private keys) must be reported to the CAP (Central Point of Contact at the National Bank) (accessed 2026-05-19).

This also applies to exchanges outside Belgium. The declaration is made via Box XIII of the personal income tax return (code 1075-89) and once via the CAP form. Non-custodial wallets (you manage your own private key) currently do not fall under the CAP reporting obligation.

DAC8 — automatic exchange

From 1 January 2026, crypto-asset service providers (CASPs) are required to report data on European users to the national tax authority, under the European DAC8 directive.
The first reporting by crypto platforms to FPS Finance is no later than 31 January 2027 (covering calendar year 2026). The first automatic exchange between EU member states follows no later than 30 September 2027.

This means that FPS Finance will then automatically have visibility over your transactions, staking activities and received rewards at regulated platforms.

Practical conclusion: do not wait for the first DAC8 reports to declare your crypto income. Staking rewards and lending interest are already taxable and declarable now.
Non-declaration risks: (a) a tax increase of 10% to 200% of the tax owed on the undeclared income (art. 444 ITC92), and (b) an administrative fine of €50 to €1,250 per missing entry of a foreign account in the return (art. 445 §1 ITC92).

Practical checklist

☐ Map your crypto share as a percentage of your total financial assets (savings + securities + crypto). Do you remain well below 25%? Then normal management is realistic.
☐ Keep a transaction log with date, amount, rate and nature of each transaction (purchase, sale, staking reward, lending interest).
☐ Record every received staking reward or lending interest with the market value on the date of receipt → this is your taxable basis for movable income (30%).
☐ Note the value of all your cryptocurrencies on 31 December 2025 (snapshot value). This is the acquisition basis for the calculation of capital gains from 2026.
☐ Declare your custodial exchange accounts in Box XIII + CAP with the NBB. One-off registration, reported again each year in the tax return.
☐ Staking rewards and lending interest: declare in Box VII, code 1444 of the personal income tax return.
☐ Do not use borrowed money to buy or stake crypto if you want to demonstrate normal management.
☐ Consider a ruling via the DVB if your situation is complex (large portfolio, DeFi, multiple protocols).

Sources & further reading

Primary and semi-primary sources

Income Tax Code 1992 (ITC92) — art. 17, 19, 90 — FPS Justice (accessed 2026-05-19)
Law of 6 April 2026 (BS 21 April 2026) — capital gains tax on financial assets — FPS Justice (accessed 2026-05-19)
DVB (Advance Tax Ruling Service) (source in Dutch) — Belgian advance ruling service (accessed 2026-05-19)

FSMA — warnings on crypto assets — FSMA (accessed 2026-05-19)

Central Point of Contact (CAP) — NBB — NBB (accessed 2026-05-19)

Wikifin (FSMA) — Cryptocurrencies: risks and regulation (source in Dutch — no English version available) — Wikifin / FSMA (accessed 2026-05-19)

Secondary sources (legal practice)

Tiberghien: Income from staking, harvesting and liquidity rewards to be declared (source in Dutch) — Tiberghien (published February 2024; accessed 2026-05-19)
DVDTaxlaw: Advance tax ruling service updates crypto questionnaire (source in Dutch) — DVD Tax Law (accessed 2026-05-19)
DVDTaxlaw: Guest lecture UGent — crypto taxation in Belgium 2026 (source in Dutch) — DVD Tax Law (accessed 2026-05-19)

Imposto Advocaten — News & analysis on crypto taxation (source in Dutch) — Imposto (accessed 2026-05-19)

Curvo: Crypto tax in Belgium — Curvo (accessed 2026-05-19)

CryptoTax.be — Belgian crypto taxes 2026 (gated) — CryptoTax.be (accessed 2026-05-19; account required for full access)

Related articles on investnow.be

Declaring crypto: Box XV vs Box VII (codes 1444, 1440 and 2440 explained) — for the exact declaration procedure (TX-09 — coming soon on investnow.be)
Capital gains tax 2026: declaration and Tax-on-Web — for calculation and snapshot value (TX-01 — coming soon on investnow.be)

Staking & Lending Crypto in Belgium: Normal Management of Private Wealth — or Not?

1. Two separate tax questions