Tax Regimes for Virtual Assets: International Practices and Prospects for Ukraine

Анотація

The article presents an in-depth analysis of international approaches to the taxation of virtual assets, covering cryptocurrencies, decentralized finance instruments, non-fungible tokens, airdrops, and hard forks. The research is based on a comparative study of tax regimes in the United States, Germany, Switzerland, Estonia, Singapore, Portugal, and Australia. The analysis addresses differences in legal definitions, rules of income and capital gains taxation, valuation methods, and the application of value-added or goods and services tax. Attention is paid to compliance mechanisms and administrative practices that influence taxpayer behavior and shape levels of adoption. To complement the legal comparison, the study incorporates empirical data from the Global Crypto Adoption Index, allowing for an evaluation of the link between regulatory clarity, tax burden, and the spread of digital assets in different countries. A special focus is placed on Ukraine, which has legally recognized virtual assets through the Law “On Virtual Assets” while awaiting the implementation of Draft Law No. 10225-д to introduce taxation rules. These reforms are assessed in the context of international standards developed by the Organisation for Economic Co-operation and Development, the Financial Action Task Force, and the European Union. The article emphasizes the risks associated with gaps between formal legislative alignment and actual enforcement capacity in transition economies. Excessive or unclear taxation is shown to contribute to capital outflow, informal practices, and regulatory arbitrage. The article further explores underregulated areas such as staking, token swaps, and the creation and trade of non-fungible tokens. It argues that updated tax guidance and coordinated cross-border measures are necessary to provide legal certainty and prevent systemic risks. The role of blockchain analytics, identity verification, and international information-exchange regimes is highlighted as a foundation for more effective oversight. The novelty of the study lies in combining doctrinal legal analysis with fiscal assessment and comparative empirical indicators, which makes it possible to identify both universal patterns and national specificities. The conclusions stress that sustainable taxation of virtual assets requires transparent, balanced, and enforceable rules supported by international coordination. Such an approach not only ensures stable public revenues but also fosters responsible financial innovation and strengthens the integration of Ukraine into the global digital economy.

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