Lending, staking, own wallets: what the BMF letter of 6 March 2025 settles, and what it does not

Anyone holding crypto-assets as business assets and doing more with them than holding meets three kinds of transactions in the books: income that arises without a sale (staking, lending), movements that look like sales but are not (moves between one's own wallets, bridges between blockchains), and deposits into contracts whose nature is unclear (lending protocols, liquidity pools). The letter of the Federal Ministry of Finance (BMF) of 6 March 2025 (IV C 1 - S 2256/00042/064/043) answers the first group with surprising precision, the second not at all, and the third only by half. Here is what it says, with the margin number (Rz.), and what is missing.

Staking: settled, with a point in time

The letter distinguishes two things that both go by "staking" in everyday language. Anyone creating blocks themselves (forging) falls under margin numbers 33 to 39. Anyone merely providing a stake without creating blocks, for instance through a staking pool or a trading platform's offering, is doing passive staking under margin number 13. The crypto-assets are locked, not transferred.

For business assets, margin number 49 says, in our translation:

"Where the locked crypto-assets belong to business assets, the rewards constitute business income. The crypto-assets received for (passive) staking are to be capitalised at the market rate at the time they arrive, increasing profit."

The market rate is the one from margin number 43, meaning the rate of a trading platform or a web-based price list, and margin number 91 allows daily rates as long as the method is documented and applied uniformly. On timing, margin number 48a says something that saves a great deal of work in practice: during the year it is not objected to if the crediting to the wallet, the claiming, is taken as the time of arrival. Rewards not yet claimed have to be recognised by the end of the financial year at the latest.

That adds up to a complete booking instruction: income at the time of crediting, valued at the documented daily rate, and at year end a look at what has not yet been claimed.

Lending: settled for the income, open for the deposit

Margin number 26 defines lending in one sentence: crypto-assets are handed over for use in return for a payment. For business assets, margin number 64 says that the income from this handing-over is business income and that the crypto-assets received for it count as acquired, valued at the market rate at the time they arrive. It refers expressly to margin number 48a, so here too the crediting to the wallet may count as the time of arrival.

So far the payment. The deposit itself is the open half. Anyone depositing stablecoins with a decentralised lending protocol such as Aave or Compound transfers them to a contract and receives, at Aave, a token of its own in return, at Compound a balance inside the contract. The letter describes decentralised finance in margin number 20a, including providing crypto-assets to a pool, but does not classify it. Whether such a deposit is a handing-over for use within the meaning of margin number 26 or an exchange into another crypto-asset is not in it. And because with these protocols the income does not arrive as a transfer of its own but grows inside the balance and only becomes visible on withdrawal, the timing question arises afresh: is the arrival the withdrawal, the continuous growth, or, under margin number 48a, the end of the year at the latest?

These are questions for the tax adviser, not for the software. What the software can do is lay out the facts cleanly: every deposit against every withdrawal per contract and crypto-asset, the amount still inside the contract, and the part of the withdrawal beyond what was deposited as candidate income. With the assumption stated: that withdrawals return the principal first. Set the assumption differently and you get a different number; that is why it is written next to it.

Own wallets: not settled, but derivable

A transfer from one of one's own wallets to another of one's own wallets the letter does not address expressly. Two passages help nonetheless. Margin number 32 attributes crypto-assets to the beneficial owner, the person who can initiate transactions, as a rule the holder of the private key. Margin number 54 defines, in the section on private assets, a disposal as a transfer to third parties for consideration. In a move between one's own wallets neither the holder changes nor is anything paid.

For the books that means: no revenue, no expense, but a transaction that has to be in the audit trail, because it is visible on the blockchain and an auditor will find it. The real question sits with acquisition cost. Margin number 51 requires, for business assets, the deduction of the individual acquisition cost, or an average where the individual cost cannot be attributed. How that is kept when holdings move between several own wallets is better settled once with the tax firm than reconsidered at every move.

The most frequent error here is technical: a tool that reads only the receiving wallet sees an inflow and books revenue. The company then pays tax on money it already had. The case can only be recognised if both addresses are known as the company's own.

Bridges: not even mentioned

The word bridge does not occur in the letter. Technically, with a bridge such as Circle's CCTP the stablecoin is destroyed on the source chain and issued anew by the same issuer on the destination chain; on the blockchain that looks like an outflow to a contract and, minutes later, an inflow from nowhere, often smaller by a fee. Whether that is, for tax purposes, a transfer of the same asset or an exchange with a disposal and a new acquisition, and how the fee is to be treated, cannot be derived from the letter. It is a question for the tax adviser, and one that begins with documentation: which outflow belongs to which inflow, and who confirmed it.

Pools: described, not classified

Margin number 20a describes that decentralised exchanges let users provide crypto-assets for exchange through smart contracts, including to a pool. A classification of the deposit against share tokens, and of the fee shares the pool pays out, the letter does not contain. Anyone providing liquidity has two open questions: is the deposit an exchange, and how are the fees to be treated?

The table

What this means for the books

A tool that processes these transactions can get two things wrong. It can pretend to know the answer and book a lending deposit as an expense or a bridge as a sale. Or it can ignore the transactions and leave them as "no rule matches" until someone books them by hand. The third way is to attach to every transaction what the letter says about it, with the margin number, and to phrase the gaps as questions the tax firm answers once and that then apply to every identical case.

That is how we built it in Stablewerk: moves between registered own wallets are recognised and not booked, bridge pairs are proposed and confirmed by a person, deposits into and withdrawals from Aave and Compound appear in review with the margin numbers and the open questions, and booking them as revenue is not offered. Staking and pools sit in the same table, even though we do not yet read income in crypto-assets other than USDC and EURC. The rule should be there before the transaction shows up.

Frequently asked

Does this also apply to private assets? For staking and lending in private assets, margin numbers 48 and 65 apply (other income under section 22 no. 3 of the Income Tax Act), and for the disposal of the crypto-assets received, margin numbers 53 et seq. This article deals with business assets.

Which rate applies on arrival? The market rate under margin number 43 from a named source, as a daily rate under margin number 91 where the method is documented and applied uniformly. How that is documented is in our German article on the rate source, "Kursquelle dokumentieren".

What about VAT? This letter is an income-tax letter. The VAT treatment of staking, lending and pools is a separate question and not the subject of this article.