Bitcoin Savings Plan and Tax: How the Holding Period, FIFO and the Exemption Limit Interact on Monthly Buys

A Bitcoin savings plan takes the timing question off your hands. You buy a fixed amount every month, whether the price is rising or falling. Tax law grants you no such convenience: twelve instalments a year become twelve separate acquisitions, each with its own date, its own price and its own clock.

For you as an investor, that has one consequence. Whether a later sale stays tax-free is decided at the level of the individual tranche and the order in which the tax authorities treat those tranches as sold, never at the level of your total holding. Sell after three years of a savings plan and you do not hold one uniform stock of Bitcoin; you hold 36 acquisitions with 36 deadlines. This article sorts out the mechanics: holding period, exemption limit, order of disposal, valuation and record-keeping, each with its source.

Why a Bitcoin savings plan consists of many separate purchases for tax purposes

A savings plan is technically a standing order to buy: the exchange executes an order on a fixed date and credits you with the fraction of a Bitcoin you have acquired. For tax purposes, each of those executions is an acquisition within the meaning of German income tax law, with its own point in time, its own acquisition cost and its own holding period.

The savings plan therefore differs from a one-off purchase only in the number of events. Invest €6,000 in a single trade and you have one deadline to watch. Invest €250 a month for 24 months and you have 24 of them. Which providers in Germany offer automated instalments at all, and at what cost, is set out in our comparison of Bitcoin savings plans. The tax mechanics behind them are identical at every provider.

The one-year holding period under Section 23 EStG runs separately for every instalment

Gains from selling privately held crypto assets are private disposal transactions. The governing provision is Section 23(1) sentence 1 no. 2 of the German Income Tax Act: disposals of other assets are taxable where the period between acquisition and disposal is no more than one year. Where more than a year passes between purchase and sale, the gain falls outside taxation.

For a savings plan, this amounts to a rolling exemption. The March 2025 instalment is out of the period from March 2026, the April 2025 instalment from April 2026. If you sell part of your holding in May 2026, one and the same sale can contain tax-free and taxable portions at once.

What “other assets” means under Section 23 EStG

That crypto assets fall under this provision has been settled at the highest judicial level and is more than administrative opinion. In its judgment of February 14, 2023 (case no. IX R 3/22), the Federal Fiscal Court held that crypto assets are other assets within the meaning of the provision; the Federal Ministry of Finance cites the judgment at margin no. 53 of its circular. In practice: no flat-rate withholding tax, no saver’s allowance, and instead your personal income tax rate on gains realised inside the one-year window.

The €1,000 exemption limit: why one euro more makes the entire gain taxable

Section 23(3) sentence 5 EStG is precise: gains remain tax-free where the total gain from private disposal transactions in the calendar year came to less than €1,000. This is an exemption limit rather than a tax-free allowance. At €999 of gain you pay nothing; at exactly €1,000 the full amount becomes taxable.

Two details are regularly overlooked with savings plans. The limit applies to all private disposal transactions of a calendar year taken together, so gold sales inside the one-year window count as well. And the figure that is tested is the total gain, never gross turnover: losses from other deadline-bound sales in the same year reduce the tax base before the limit is applied.

Order of disposal: individual identification, FIFO and the average-cost method

When you sell out of a holding built from many instalments, it has to be clear which tranche counts as disposed of. The Federal Ministry of Finance circular of March 6, 2025 on individual questions of the income tax treatment of certain crypto assets settles this at margin no. 61, in three steps.

The starting point is individual identification: where the specific unit can be allocated individually, that unit counts as sold. Where this is not possible, the crypto assets of a given trading designation acquired first are deemed disposed of for the purposes of the holding period, and the average-cost method applies to the valuation. As a simplification, you may assume that the units acquired first were sold first, that is first in, first out.

In practice this means the order of purchase is unavoidable for the deadline, while for valuation you have a choice between the average-cost method and FIFO. On a savings plan that has been running for years, that choice quickly amounts to a three-figure sum, because the early instalments were executed at prices far removed from the later ones.

Wallet-by-wallet treatment: why the spread of your purchases across wallets counts

The order is not formed across your entire holding. Margin no. 61 makes clear that a wallet-by-wallet view applies. Within a wallet, the chosen method has to be retained until all crypto assets of that trading designation there have been sold in full; only after a subsequent new acquisition may you switch. If you later move holdings to your own wallet in portions, document those transfers. Without a record of which tranche went where, individual identification drops out as an option.

The ten-year period for currency tokens: why lending does not tie up your savings plan holdings for longer

Section 23(1) sentence 1 no. 2 sentence 4 EStG extends the period to ten years where income is generated from an asset in at least one calendar year. For a long time it was open whether staking or lending would therefore burst the one-year window for Bitcoin. Margin no. 63 of the circular answers this unambiguously: for currency or payment tokens, that extension does not apply.

The income itself is untouched by this. The circular allocates lending income to other income under Section 22 no. 3 EStG at margin no. 65, and the crypto assets received for it count as acquired at the moment they accrue. A fresh one-year period therefore starts for the income.

Daily price and price source: how you may value a monthly instalment

A savings plan instalment is rarely executed at a round price. Margin no. 91 therefore permits you to apply a daily price determined according to documented rules instead of the market price at the moment of execution, provided a consistent valuation is ensured. The daily average price, a fixed time of day and the daily closing price are all admissible.

Consistency is missing, according to the same margin number, where you draw on different sources or different points in time for acquisition costs and disposal proceeds. Settle on one price source and one time of day, and hold to both for the entire term.

Record-keeping duties: what the tax office expects after five years of a savings plan

Part III of the circular deals for the first time in detail with filing, cooperation and record-keeping duties. Margin no. 89 gets specific: where crypto assets are bought or sold through the centralised trading platforms of a foreign operator, this triggers an extended duty to cooperate under Section 90(2) of the Fiscal Code. That expressly includes retrieving transaction statements regularly and in full.

The sentence that matters most to savings plan investors comes at the end of the same margin number: missing records and data losses, for instance through the insolvency of a platform, are borne by the taxpayer. Margin no. 29a adds that retrieval is limited in time at some providers. Anyone who runs 60 instalments over five years and goes looking for the documents only at the point of sale carries that risk alone.

Tax reports and portfolio trackers: what they deliver and where their limit lies

Margin no. 29b of the circular describes the tax reports of private-sector providers with remarkable sobriety. Such reports resemble the tax certificates issued by banks on the surface, but they are built on wallet information and transaction statements that the taxpayer supplies. Their completeness therefore depends materially on the underlying data, and the results can be adjusted manually.

A report therefore carries none of the authority of a tax certificate. It is a calculation aid resting on your own data. For a savings plan with many small tranches it remains the most sensible tool nonetheless, because it carries the holding period forward for each individual tranche. A look at the comparison of crypto tax tools and portfolio trackers pays off above all on the question of whether the tool maps wallet-by-wallet methods and method retention cleanly at all.

Fees, spread and selling costs: what reduces the taxable gain

Under Section 23(3) sentence 1 EStG, the gain is the difference between the disposal proceeds on one side and the acquisition costs plus income-related expenses on the other. Order fees on a savings plan execution increase the acquisition costs; transaction fees on disposal are to be taken into account as income-related expenses under margin no. 59.

With percentage-based fees, this adds up over the years to an amount that noticeably reduces the taxable gain. The condition is that the fee per execution is evident from your records. At providers who price their margin into the spread, the cost is already contained in the execution price and therefore in the acquisition costs.

Loss offsetting: why savings plan losses only run against private disposal transactions

Section 23(3) sentence 7 EStG limits the offset: losses may be set off only up to the amount of the gain you realised from private disposal transactions in the same calendar year, and a deduction under Section 10d EStG is excluded. Sentence 8 allows a carry-back to the immediately preceding year and a carry-forward to future years, in each case again only within the same category of income.

A loss from a savings plan sale cannot be offset against your salary or against gains on shares. One further point matters: a loss after the one-year period has run is irrelevant for tax, because the transaction is no longer taxable. If you want to close out a position at a loss, you need to know which tranches are still inside the window.

The 2026 holding period debate: what savings plan investors should factor in now

The one-year period is politically contested. On August 9, 2026, CryptoTicker summarised the state of the discussion around abolishing the holding period and the associated Bundestag petition, in the article Germany’s crypto holding period faces abolition. What governs your tax return until further notice is the statutory text, and that still contains the one-year period unchanged. Any change presupposes an amendment to the Income Tax Act.

When a new rule would take effect, and whether existing holdings would be protected, is open and cannot be responsibly anticipated. The only thing you can steer today is your documentation. Anyone who keeps acquisition dates, price source and wallet allocation in good order will cope with any conceivable transitional rule.

What to take away

1. Keep a tranche list from the very first instalment. Date, amount, quantity, execution price, fee and wallet all belong in it. Which providers run savings plans with traceable statements is shown in the savings plan comparison.
2. Fix the valuation method once per wallet and stick to it. Average cost or FIFO, one price source, one time of day. A tool that maps wallet-by-wallet methods is in the comparison of crypto tax tools.
3. Retrieve your transaction statements every year and archive them yourself. The extended duty to cooperate applies at foreign platforms, and data losses are borne by you. Which trading venues are regulated is set out in the comparison of regulated crypto exchanges.

(As of August 11, 2026. This article is not investment advice. Prices and fee structures change; check the terms with the provider before you buy. This text is no substitute for individual tax advice.)