Hacienda and Crypto in Spain: Which Operations Trigger Reviews in 2026
Educational material; for complex cases and larger amounts, it’s best to involve a tax/legal specialist in Spain.
Hacienda is the common shorthand for Spain’s tax authority, Agencia Tributaria. It administers taxes, receives filings, and—when data doesn’t line up—requests clarifications and supporting documents.
In 2026 it’s become easier for Hacienda to assemble the “crypto puzzle”: bank flows, provider reporting, and your tax filings increasingly connect into one picture. Questions usually start with mismatches—amounts don’t reconcile, activity looks regular, the source of funds is explained verbally but not documented, or some assets sit “outside” Spain with no clear linkage.
What Hacienda Can See: Models 172/173/721
Modelo 172 — provider reporting on crypto balances held in custody (what you hold on the platform on the reporting date).
Modelo 173 — provider reporting on user operations (the scope and detail depend on what the provider is required to disclose).
Modelo 721 — an information return for virtual currencies held abroad: an additional control layer for assets located outside Spain.
Where Questions Most Often Start
Below are the common scenarios that lead to document requests or explanations in 2026.
1) Bank cash-out: a large amount without a clear trail
The most frequent pattern: a noticeable EUR transfer to a Spanish bank, followed by a request (often from the bank first) to explain the transaction chain and the source of funds.
Typical risk signals:
- a sharp jump: nothing for a long time, then one large incoming transfer;
- no readable route “deposits → trades → withdrawal”;
- payment references and history don’t show a clear origin story.
2) P2P looks like exchange activity
P2P isn’t automatically illegal, but it’s noisy from a compliance perspective. A bank sees many transfers from many individuals rather than one clean payment to a provider.
Common triggers:
- many similar incoming/outgoing transfers to a card/account;
- dozens of counterparties and repeated amounts;
- payer/payee names that don’t align with the transaction logic;
- volume and frequency that resemble a “mini exchange desk”.
If P2P is a recurring route, track it like ongoing financial activity: counterparty, order ID, amount, date, payment rail, and confirmation inside the order. Avoid moving settlement into private chats outside the platform.
3) Too many operations: swaps, exchanges, active trading
In Spain, taxable events may arise not only when you cash out to EUR, but also on crypto↔crypto exchanges (permuta). Active users can have hundreds or thousands of swaps—this is where “eyeballing it” breaks.
Red flags:
- many swaps/trades without a consistent accounting method;
- missing links between purchases, transfers, and disposals;
- calculations are approximate and not reproducible from the data.
4) Staking, lending, referral rewards
Regular credits stand out even if amounts are small. A repeating source plus predictable timing creates a clear pattern. Record reward dates, income type, valuation/FX rate on the date, and fees. Keep proof of the source (platform/protocol, reports/exports).
5) Foreign exchanges and “outside” custody
When part of your holdings sit with a foreign provider, checks become cross-referential: balances, operations, and bank flows are expected to reconcile. This is where Modelo 721 often becomes the additional control layer for assets held abroad.
6) A mismatch with everyday spending
If bank behaviour suggests one level of living expenses while declared income looks materially lower, a large crypto operation becomes an easy entry point for questions—because it’s straightforward to formalize and request documentation for it.
How to Reduce the Chance of a Review
- Keep one evidence folder
CSV/statements, TX hashes, balance screenshots on key dates, bank statements.
2. Make the route readable
Deposit → trades → withdrawal. If you moved assets between exchanges/wallets, bridge the steps with TX links.
3. Reduce P2P noise
Fewer counterparties, only within the platform, no third-party bank details.
4. Separate regular income streams
Staking/lending/referrals: a dedicated sheet with dates and EUR valuation.
5. Use infrastructure where reporting is painless
The easier it is to export history and reconstruct flows, the lower the risk of “memory-based” inconsistencies. In the Hexn ecosystem, you can treat this as an operational layer—custody, conversion, and transfers with a clear transaction history—so you have a ready package if a bank or Hacienda asks.
Conclusion
In 2026, consistency across data matters. If you cash out to a bank, keep the route and documents ready so you don’t have to rebuild the story after the fact. If you rely on P2P, cut the unnecessary noise and keep every deal inside the order flow. If you trade and swap actively, a proper transaction log and a defensible calculation method save time and friction. When the history is clean, most questions end quickly.