The Greek parliament has passed a crypto tax framework. Capital gains are taxed at 10%, while staking and DeFi income are taxed at 15%. The tax only applies once annual earnings exceed €500 (about $557).

By EU standards, these rates aren’t high. Germany exempts gains on crypto assets held for more than a year, France imposes a flat 30% tax on capital gains, and Italy charges 26%. Greece’s rates of 10% and 15% suggest it wants to bring crypto activity into the tax reporting system without scaring people away.

But what really made me pause was something else: the rules for token swaps weren’t specified.

Swapping ETH for USDC is one transaction on-chain. But what is it for tax purposes? Greek lawmakers left that question unanswered. Is it a taxable disposal, or an exchange of like-kind assets, with tax deferred until conversion to fiat? There’s no answer.

This isn’t just a Greek problem. Across the EU, even after MiCA (the Markets in Crypto-Assets Regulation) came into force, tax rules are still set country by country. Germany treats staking rewards as “other income” and exempts sales after a year of holding; France taxes staking income at 30%; and Italy’s 26% capital gains tax covers staking and DeFi. Greece has now opted for 15%—lower than France and Italy, but stricter than Germany’s tax-free route for long-term holdings.

The €500 tax-free threshold is also worth a closer look. Greece sets the cutoff at €500 in annual earnings, which means small retail investors probably won’t have to file. But DeFi earnings accrue transaction by transaction: a €20 mining reward here, a €3 staking payout there, and it’s easy to cross the threshold over the course of a year.

The problem is that Greek tax law doesn’t clarify how these small amounts of income should be aggregated. By wallet? By protocol? Or across all of a taxpayer’s on-chain activity for the year? It doesn’t say.

While reviewing the data, I noticed that Greece’s framework and Russia’s newly finalized rules arrived almost back to back. Russia is allowing retail investors to trade BTC, ETH, and USDT through regulated intermediaries, and the Moscow Exchange plans to launch in December. Both countries are doing the same thing: fitting crypto activity into existing financial regulatory and tax systems.

But while the pipes are connected, no one has decided where the valves go.

The ambiguity around token swaps is no small matter for DeFi users. If you swap ETH for USDC on Uniswap and the Greek tax authority considers that a “disposal,” then the 10% capital gains tax would be calculated based on the price at the time of the swap. But the USDC you received is still sitting in your wallet—you haven’t converted it to euros, yet the tax bill has arrived.

Users in France and Italy have already run into this kind of cash-flow mismatch. Greece has left the same trap in place.

The 15% tax rate on staking income is clear enough. But how is “staking income” calculated—using the coin’s price when the reward is received, or its price at year-end? Greek tax law doesn’t say.

I’ve been watching this figure for a while: the reporting burden associated with the €500 threshold may affect user behavior more than the tax rate itself.

A retail investor in Athens who earns €600 a year has to file taxes; someone who earns €400 doesn’t. That €200 difference is enough to tempt people to spread their activity across multiple wallets.

Greece isn’t the first EU country to leave gaps in its DeFi tax rules, and it won’t be the last. MiCA governs licensing and disclosure; taxation follows a different set of rules. Where those two sets of rules don’t line up—that’s where things stand now.

I still haven’t figured out whether token swaps should be taxed at the moment of exchange. If they are, DeFi composability becomes a string of taxable events. If they aren’t, how do you prevent people from deferring tax indefinitely through swaps?

Greece has left that question for the next set of implementing rules. Or the next government.