He warned that this proposal, if passed as is today, will hit the less crypto-savvy retail users hard, and they usually have less technical experience with crypto and taxes.
“This will hit normal consumers/investors particularly hard. People who don’t even notice this regulatory change, who can’t technically provide their acquisition costs in a clean way, and who in recent years have sometimes bought with little profit or even at a loss,” Hansen explained.
Hansen highlighted that the implicit assumption of prices doubling seems high for him, as Bitcoin is at a lower price than a year ago, and other crypto assets have underperformed during this period.
“In my view, the average Joe will end up paying far too much tax if this isn’t adjusted, especially if – as I fear for many – he can’t provide his acquisition costs in a clean and convincing way,” he concluded.
Nonetheless, Dr. David Hötzel, Associated Partner at Poellath, pointed out that this 50% consideration is not final, but it acknowledges that it creates significant liquidity risks. Nonetheless, Hötzel acknowledged that this would affect transfers from self-custody wallets or foreign platforms to German exchanges, subject to deductions.
As a result, Hötzel highlighted that “the protection of existing holdings effectively depends on reliable documentation,” as this tax base can trigger a high provisional deduction even in low actual profit cases, siding with Hansen’s assessment.

