📝 Description
Since 2023, Italy has created specific tax rules for crypto-assets. Within this framework, lawmakers have occasionally opened “revaluation windows”: opportunities for taxpayers to reset the tax cost of their crypto by paying a flat substitute tax.
👉 This mechanism is known as the step-up (rivalutazione/affrancamento).
📂 1. What is the legal basis?
Budget Law 2023 (Law no. 197/2022, art. 1, paras. 133–137): introduced the first revaluation option for crypto, setting the tax cost at the value on 01/01/2023 by paying 14%.
Budget Law 2025 (Law no. 207/2024, art. 1, paras. 94–100): reopened the mechanism, this time on the value at 01/01/2025, with a substitute tax of 18%.
These provisions tie back to Article 67(1)(c-sexies) TUIR, which defines taxable capital gains on crypto-assets.
⚠️ This is not a permanent regime. Each step-up window is explicitly created by a specific Budget Law.
📂 2. What is the step-up?
The step-up allows you to replace your historical acquisition cost with the market value as of January 1, 2025 (valore normale under Article 9 TUIR).
In exchange, you pay a substitute tax of 18% on that value.
This new cost basis is then used for all future capital gain calculations.
📂 3. Is it mandatory?
No ❌.
The step-up is optional.
It applies asset by asset (per ciascuna cripto-attività). You can choose to apply it to your BTC but not to your ETH.
Once chosen, the option is irrevocable.
📂 4. Can I use it to lock in a loss? 📉
No.
If the value on 01/01/2025 is lower than your historical purchase cost, you cannot apply the step-up.
This mechanism is not a “step-down.” It only serves to increase the fiscal cost basis, never to generate a tax loss.
📂 5. How do I pay and when?
Reference date: crypto must be held on 01/01/2025.
Rate: 18% on the value at 01/01/2025.
Payment: via F24 form, using the codes published by the Italian Revenue Agency (Agenzia delle Entrate).
Either in one payment by 30 November 2025,
Or in 3 annual installments (2025, 2026, 2027) with 3% interest on the second and third payments.
Declaration: in future years, you will declare sales in Quadro RT, using the new cost basis fixed by the step-up.
💡 6. A concrete example
Without step-up
Bought: 1 BTC in 2019 at €5,000.
Sold in 2026 at €30,000.
Taxable gain = 30,000 – 5,000 = €25,000.
Tax = 33% × 25,000 = €8,250.
With step-up
01/01/2025: BTC market value = €20,000.
Step-up: substitute tax = 18% × 20,000 = €3,600 (paid in 2025).
Sale in 2026: taxable gain = 30,000 – 20,000 = €10,000, taxed at 33% = €3,300.
Total paid = 3,600 + 3,300 = €6,900.
👉 Savings compared to the “no step-up” case: €1,350.
📂 7. Can I do it every year?
No.
2023: one-off window at 14%.
2024: no revaluation option.
2025: new window at 18%.
2026 and beyond: nothing is guaranteed. A future step-up would require a new Budget Law.
👉 Step-up should be seen as an occasional opportunity, not an annual routine.
The step-up is most useful if:
Your historical purchase price is much lower than the market value on 01/01/2025,
You plan to sell relatively soon (especially since the tax rate rises to 33% in 2026).