Crypto asset transactions: International experience and implications for Viet Nam

This creates legal ambiguity and complicates the determination of taxpayers’ obligations. She emphasizes that a clear and well-structured tax policy for crypto assets is essential—one that recognizes their unique characteristics while ensuring administrative feasibility and consistency with economic principles.

Such a policy, she argues, must begin with defining and classifying different types of crypto assets, including highly liquid cryptocurrencies, utility tokens, NFTs, stablecoins, and DeFi products. It must also apply the core principles of a modern tax system—neutrality, fairness, transparency, practicality, and sound risk management.

Furthermore, the policy should coordinate multiple tax instruments, such as income and capital gains taxes, indirect taxes on intermediary services, and property taxes where applicable, to fully capture the economic substance of crypto transactions. Tax administration must also align with Viet Nam’s broader digital transformation agenda, ensuring that policy implementation is both effective and technologically feasible.

International Experience

According to Ms. Nguyệt, countries that have developed effective crypto tax regimes began by clarifying the legal nature and classification criteria of crypto assets. The United States treats cryptocurrencies as property and applies capital gains tax rules similar to those governing securities. Australia classifies them as taxable assets under its capital gains tax regime. India defines them as Virtual Digital Assets, while Singapore distinguishes between utility tokens, NFTs, stablecoins, and DeFi income such as mining, staking, or airdrops.

Despite differences in legal interpretation, most countries share a common trend: highly liquid tokens are managed as investment assets, while stablecoins and utility tokens are taxed primarily when used for transactions or consumption. Developed countries also apply the fundamental principles of neutrality, fairness, and transparency. For example, the United States and Australia allow the offsetting of crypto-related losses against other capital assets, thereby reducing distortions in investment decisions. In contrast, India and Japan prohibit such offsets and impose high tax rates—up to 55 percent in Japan and 30 percent in India—reflecting a conservative and revenue-maximizing stance.

On the other hand, Singapore and Switzerland have adopted more pro-innovation policies by exempting long-term capital gains from taxation. Australia offers a 50 percent capital gains discount for assets held longer than twelve months, and Germany exempts crypto held for more than a year. These examples suggest that balancing revenue collection with investment promotion is crucial, and that time-based or rate-differentiated approaches can help achieve that balance.

Many countries have also integrated multiple tax instruments to reflect the full economic nature of crypto transactions. Income and capital gains taxes serve as the main pillars, while indirect taxes such as VAT or GST are applied to intermediary services like exchanges, wallet providers, or mining operations when deemed service activities. Some jurisdictions have gone further by introducing special measures, such as an annual wealth tax in the Netherlands or small-transaction exemptions in France and Australia. These approaches demonstrate that multi-tax coordination can broaden the tax base and ensure that taxation reflects economic substance rather than transaction form.

Implementation mechanisms are also an integral part of successful crypto taxation systems. India applies a one percent Tax Deducted at Source (TDS) on all transactions, establishing an automatic reporting and monitoring mechanism. The United States and Australia require detailed reporting of each transaction and have built software ecosystems to facilitate taxpayer compliance. In Europe, some countries prioritize simplification: Germany tracks only holding periods, the Netherlands taxes based on annual asset value, and Singapore differentiates between professional traders and long-term retail investors, focusing enforcement on the former while exempting the latter.

Flexibility, Ms. Nguyệt adds, is a decisive advantage. Australia’s “personal use exemption,” which excludes gains from transactions under 10,000 AUD used for personal consumption, simplifies compliance for ordinary users. Singapore’s capital gains exemption has turned the city-state into a global crypto hub. Conversely, Japan and India’s rigid tax regimes have driven investors toward more accommodating jurisdictions.

Finally, she stresses that technological capacity and inter-agency coordination are vital. In the United States and Europe, tax administrations are accelerating digitalization, integrating oversight with AML/KYC frameworks, and requiring standardized data reporting from exchanges. These reforms underline that administrative capacity and digital infrastructure determine the effectiveness of crypto taxation policies.

Policy Implications for Viet Nam

For Viet Nam, Ms. Nguyệt notes, crypto assets represent both a challenge and an opportunity. Their decentralized and volatile nature complicates monitoring, yet it also compels policymakers to innovate and align more closely with global practices. Viet Nam needs a coherent legal and tax framework that both mitigates risk and encourages innovation. Tax policy should be fair, neutral, transparent, and feasible to implement, with a gradual roadmap beginning with pilot programs or sandboxes before scaling nationally and integrating with international standards.

The foundation of this framework must be a clear and flexible classification system for crypto assets. Effective taxation depends on identifying and differentiating between the economic characteristics of each asset type. Instead of placing all crypto assets into a single legal category, Viet Nam should adopt a flexible mechanism allowing tax authorities to classify assets as securities, commodities, or payment instruments based on their use and nature, following the approaches of countries such as Singapore and Australia. Highly liquid coins like Bitcoin could be treated as commodities, while fundraising tokens might be regulated as securities, as practiced in Thailand.

She also emphasizes the need for detailed tax guidance on complex transactions such as staking, airdrops, and token swaps, to define taxable events and provide clarity for taxpayers. This would improve transparency and minimize unintentional non-compliance, following the examples of the United States and the European Union.

Given the cross-border and decentralized nature of the crypto market, Viet Nam should also adopt a management strategy that goes beyond traditional tax mechanisms. Domestically, exchanges and virtual asset service providers should be required to report transaction data for tax monitoring and verification. Internationally, Viet Nam should actively participate in cross-border tax cooperation frameworks, negotiate information-sharing agreements, and harmonize its regulations with those of partner countries to prevent tax avoidance through offshore platforms.

Finally, tax policy must ensure fairness while promoting innovation. Transactions involving crypto assets should be taxed based on their true economic nature, applying the same principles used for equivalent traditional financial transactions. At the same time, Viet Nam must strengthen institutional capacity, invest in staff training, and modernize its digital tax administration tools to ensure that tax authorities can effectively monitor, analyze, and enforce compliance.

As Ms. Nguyệt concludes, developing a crypto tax regime for Viet Nam requires a strategic, step-by-step approach grounded in clear classification, multi-layered enforcement, international cooperation, and fairness-driven innovation. A prudent but forward-looking policy framework will enable Viet Nam to harness the opportunities presented by crypto assets while minimizing financial and legal risks, paving the way toward full integration with international tax governance standards.