CryptoReflexions#17 - Tax Data Super-Database & Crypto-Assets

Posted on Nov 1, 2025

Hello everyone,

Today, a reflection on a Belgian legislative project that deserves attention: the merger of the Central Contact Point (PCC) with the tax authority’s data warehouse — with crypto-assets in the crosshairs.

Interested?

Let’s go!

The Project in Brief

The Belgian government is advancing a bill that authorizes the automated exploration of data combining banking information and tax data. This is no longer reactive tax control, but proactive surveillance based on data mining and algorithmic profiling.

The tax administration no longer merely controls suspicious behavior — it detects it by algorithm.

Crypto-Assets Explicitly Targeted

The legislation explicitly extends the PCC’s obligations to crypto-asset service providers (CASPs). They will have to declare:

  • The existence of accounts for Belgian users
  • Semi-annual balance statements
  • Data aligned with MiCA regulation (EU 2023/1114)

Entry into force deadline: December 1, 2026.

Providers will have to declare holdings retroactively as of December 31, 2025 and June 30, 2026, before full compliance is required by the end of 2026.

The Belgian Council of State recognizes the need for a legal basis, but expresses reservations about the lack of predictability and proportionality of the envisaged measures.

The Data Protection Authority (DPA) goes further: it fundamentally opposes the transfer to the data warehouse, for lack of sufficient demonstration of necessity.

What This Changes for Crypto Holders

This transformation creates a global financial surveillance infrastructure. In concrete terms:

  • Your crypto holdings will be known to the tax administration via your regulated service providers
  • Data will be automatically cross-referenced with your tax returns
  • Any discrepancy could trigger an audit without prior human intervention

Conclusion

This project illustrates a fundamental trend: tax transparency no longer relies on voluntary declaration, but on automated collection. For crypto-asset holders, the consequence is clear — documenting, declaring, and anticipating becomes a necessity, not an option.

To go further: cryptomonnaie.be — The cryptocurrency blog in Belgium | Newsletter CryptoBelgique — Stay informed about news and updates

Florian ERNOTTE Lawyer 👉more infos about what i do