How does the Spanish tax agency know I have a cold wallet? The truth about tracing in 2025

Víctor Lázaro

Víctor Lázaro

3 min read

How does the Spanish tax agency know I have a cold wallet? The truth about tracing in 2025

If you use a Ledger, a Trezor or any other cold wallet, you probably assume your crypto is invisible to the Spanish tax agency. During the Renta 2025 filing season, however, the AEAT has sharpened its tracing methods considerably.

At Cryptoimpuestos, a firm co-founded by specialists such as Víctor Lázaro and Rafael González López, we help hundreds of people put their tax affairs in order. Today we explain, without the jargon, how the tax agency pulls on the thread until it reaches your private device.

1. The exchange tip-off (the KYC trail)

Most people buy their first coins on platforms such as Binance, Kraken or Bit2Me. To get in, you had to go through a KYC process (identity verification with your ID document).

When you send funds from the exchange to your cold wallet:

  1. The exchange records the destination address.
  2. Thanks to Modelo 172 and Modelo 173 (and the European DAC8 directive), the tax agency is told that you, by name and surname, have moved funds to an external wallet.

2. The trail left by your bank account

The tax agency does not only look at the blockchain; it looks at your bank. Any transfer from your Spanish account to an exchange is on record. If you sent €5,000 to an exchange and the money never came back to your bank, nor appeared on your tax return, the agency raises a flag for an unjustified increase in net worth.

Diagram of the banking trail connecting bank transfers to crypto exchanges for the Spanish tax agency in 2025

3. The blockchain is a public ledger

Your cold wallet does not have your name written on it, but the blockchain is public. Once the tax agency links one of your addresses to you (through a withdrawal from an exchange, for instance), it can see every movement of that wallet:

  • How much you hold.
  • Which DeFi protocols you connect to.
  • Whether you have received airdrops or staking rewards.

At Cryptoimpuestos we process that on-chain traceability so that your profit and loss report matches exactly what the tax agency is already seeing on the network.

4. Modelo 721 and international transparency

Since 2024, Modelo 721 has required crypto-assets held abroad to be reported once they exceed €50,000. Strictly speaking a cold wallet is not “abroad” (you hold the keys), but the trail you left to fund it usually comes from platforms outside Spain that already share data with the AEAT.

World map of the automatic exchange of tax information on crypto between countries under Modelo 721

How to stay out of trouble this year

The point is not to hide the cold wallet, but to prove where the funds came from. If the tax agency asks, you have to show what money you bought that crypto with and what you have done with it since.

At Cryptoimpuestos we take care of:

  • Bringing your activity together: we merge the data from your exchanges and your private wallets.
  • Calculating your P&L: we produce the profit and loss report under the FIFO method.
  • Filing on your behalf: we submit your forms to the tax agency for you.

Do not leave your peace of mind to chance

If you have a cold wallet and are not sure how to report it, do not wait for a formal demand to arrive. Cryptoimpuestos is the leading independent firm in Spain for these complex cases.

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Cold Wallet Spanish tax agency Crypto tax Blockchain tracing Modelo 721
Víctor Lázaro

Víctor Lázaro

Tax adviser, Cryptoimpuestos.es

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