(AGENPARL) – Mon 07 April 2025 Financial and Tax Regulation for the Digital Era:
Charting the Path Forward
Speech by Chiara Scotti
Deputy Governor of Banca d’Italia
Speech at the Conference
‘The interplay between tax and financial regulation in a new digital environment’
Rome, 7 April 2025
Good morning, ladies and gentlemen. I would like to welcome you all to Banca d’Italia
and thank the Global Tax Policy Center at the Institute for Austrian and International
Tax Law of Vienna University for jointly organizing this conference to discuss the vital
link between financial regulation and taxation in the new digital world.1
I will focus on three key challenges faced by financial regulators and tax policymakers,
highlighting potential synergies, open issues and possible solutions.2 These are, first,
the definition of general principles that financial regulation and taxation should
follow to achieve their goals in dealing with the new digital environment. Second, the
delineation of the scope of financial regulation and tax policies, with emphasis on their
coherence and consistency in order to ensure they are clearly understood by market
operators, investors and customers, and can be effectively enforced. Third, the need
for international cooperation and cross-sectoral coordination to leverage potential
synergies and to avoid regulatory and tax arbitrage as well as other unintended
consequences and unnecessary complexity.
I will argue that we need an innovative and proactive approach that is able to intercept
and pivot technological and market developments as they occur, while addressing
The link between regulation and taxation in addressing market inefficiencies is well known in public
economic theory – see, among others, A.H. Barnett, B. Yandle, ‘Regulation by Taxation’, in J.G. Backhaus,
R.E. Wagner (eds.), Handbook of Public Finance, Springer, Boston, MA, 2005. Regulation and taxation
have always played a significant role in the smooth functioning and evolution of the financial and
payment industries, and have often been used in parallel to address market inefficiencies or to create
incentives aimed at pursuing relevant policy objectives, such as the growth of specific markets or
sectors, particularly in their initial stage of development. On the possible role of taxation within the
more general regulatory framework for digital assets, see R. Avi-Yonah, M. Salaimi, ‘A New Framework
for Taxing Cryptocurrencies’, Tax Lawyer, 77, 1, 2003; Financial Stability Board (FSB), IMF-FSB Synthesis
Paper: Policies for Crypto-Assets, 7 September 2023; Banca d’Italia, ‘Decentralized Technology in
Finance and Crypto-assets’, Communication of June 2022.
With thanks to Alessandra Sanelli, Mattia Suardi, Mariano Siani and Giorgio Merlonghi for their
valuable contributions.
the unique challenges and risks of digital payments and financial services.3 This will
help regulators develop forward-looking supervisory measures that balance financial
stability with innovation and efficiency, while enhancing the effective management
of money laundering risks and the proper fulfilment of tax obligations. In doing so,
rulemaking should seek to be simple and plain.
Two main factors make this a daunting task. First, the technological complexity of the
digital environment requires regulators and tax authorities to develop new expertise.
Second, the real-time nature and composability of the new digital landscape pose
unprecedented legal and operational challenges. This is especially true for decentralized
finance (DeFi), where different technological layers – including smart contracts,
protocols, interfaces and crypto-assets4 – are combined to create new products and
services, potentially bypassing traditional financial intermediaries as well as new service
providers.
Regulation and taxation: common principles and sector-specific goals
The first challenge is to identify the common principles shared by regulation and taxation
and how these combine with their sector-specific goals. Consistency and coherence
between taxation and regulation are necessary to achieve effectiveness and encourage
innovation. A robust regulatory framework for digital assets can be ineffective if the tax
framework is ambiguous, making rules on paper useless in practice. Similarly, fair and
neutral taxation of digital assets will not be able to support the safe and sound growth
of the industry if the regulatory approach is unclear, inconsistent or overly restrictive.5
Complementarity and mutual reinforcement become particularly important as regulators
and tax policymakers face the complexity of the new digital environment.6
Other common principles for regulation and taxation include certainty and clarity
– knowing exactly what the rules are, what is expected of them, and what consequences
might arise if they are not followed; time consistency – policies should remain stable
over time to allow businesses to make long-term decisions and investments, while being
flexible enough to adapt to continued innovation; simplicity – rules should be easy to
understand and apply. Introducing new rules for digital assets could offer regulators a
chance to rethink and simplify existing rules for traditional assets too. Finally, regulation
and taxation should respect technological neutrality – in principle, rules should not
C. Scotti, ‘Journey to the future of the financial system’, speech at the 31st ASSIOM FOREX Congress, 2025.
Crypto-assets are digital representations of values or of rights that can be transferred and stored
electronically using distributed ledger technology (DLT) or similar technology. See FSB, High-level
Recommendations for the Regulation, Supervision and Oversight of Crypto-Asset Activities and Markets,
17 July 2023; Regulation (EU) 2023/1114 of the European Parliament and of the Council on markets in
crypto-assets (MiCAR).
FSB, IMF-FSB Synthesis Paper: Policies for Crypto-Assets, 2023.
In some instances, taxation might play an active role, complementing regulation in orienting market
developments and choices. For instance, tax rules could align with the different regulatory treatment
of specific types of digital assets, depending on their risk profile and/or the environmental impact of
the underlying technology. See K. Baer, R. De Mooij, S. Hebous, M. Keen, ‘Taxing Cryptocurrencies’,
IMF Working Paper, June 2023.
necessarily favour one technology over another.7 Since digital assets have unique features
that make traditional approaches harder to apply, they create challenges for regulators
and tax authorities. Technological neutrality should not be understood as an abstract
concept: legal rules need to be adapted to innovation.8
Sector-specific goals for financial regulation traditionally include consumer and investor
protection, market integrity, financial stability, the smooth operation of payment systems,
and the prevention of money laundering and terrorist financing. These goals also apply
to digital services, products and the resulting business models. However, ‘traditional
vulnerabilities’ may be exacerbated in the digital context – operational risks, cyber and
data security could become bigger challenges – and increased complexities might require
new supervisory approaches – for example, SupTech9 – as well as a continued dialogue
with market participants and innovators to intercept changes in a timely manner and
build effective and cutting-edge solutions.10
Sector-specific objectives for taxation hinge on defining clear rules to ensure that income
from digital assets is taxed fairly and that potential opportunities for tax evasion are
curbed. Fairness in taxation implies that values deriving from digital assets should be
included in tax bases following the ‘ability-to-pay’ principle.11 Fighting tax evasion can
be particularly challenging. The anonymity, a-territoriality and decentralized nature of
some crypto-assets, which may allow individuals and businesses to hide transactions,
create opportunities to evade taxation, much like cash payments do.12 Digital assets
and services can also make tax enforcement difficult. Traditional tax reporting and
enforcement models that rely on ‘third parties’ to track income do not work well in the
digital world. Digital services are not always provided by traditional financial institutions:
some actors are hard to identify, especially if they are located in other countries. And
even if they can be identified, transaction data can be spread across different sources due
to decentralization and peer-to-peer transactions.
The principle of technological neutrality should not be confused with the concept of neutrality that
is typical of tax systems. The former means that regulation should be applied uniformly to different
technologies, avoiding distortions that could stifle or indiscriminately promote innovation. The latter
means that the tax system is neutral when it does not distort taxpayers’ behaviour and decisions.
For instance, currently in most countries the application of withholding taxes on earnings from
traditional financial instruments relies on financial intermediaries acting as ‘tax agents’. Conversely, in
the case of tokenized financial instruments, the possibility to bypass financial intermediaries and hold
the assets directly makes it necessary to identify new tailored ways to apply taxes.
Supervisory technology or SupTech is the use of innovative technology to support supervisory
processes.
The need for a continued dialogue with innovators to build effective and efficient supervisory tools
has been highlighted, among others, by C. Skingsley, ‘Working together to ensure financial integrity’,
speech at the BIS Innovation Hub’s 2025 Analytics Showcase, London, 27 March 2025.
The ‘ability-to-pay’ principle states that individuals should contribute to public expenses through
taxes applied on bases that can be regarded as indicators of their well-being, economic power or
capacity, such as income, wealth, expenses. It is strictly related to other principles, in particular those
of solidarity and equality, of which the ability to pay is both an application and a development in the
field of taxation.
This can be the case of unbacked crypto-assets, which represent by far the largest share of the market,
are often held for speculative purposes and, in some instances, are more prone to be used for illicit
activities.
To achieve their goals in the digital financial and payment landscape, regulators and tax
policymakers across different jurisdictions have taken a variety of approaches.
The European Union has made significant strides in regulating digital finance, launching
the Digital Finance Strategy in 2020.13 Key initiatives encompass the regulation on markets
in crypto-assets (MiCAR) and the DLT pilot regime for tokenized financial instruments.14
The overarching aim is to enable the development of digital assets and services while
ensuring a high level of consumer protection, transparency, market integrity and financial
stability. To this end, MiCAR includes an ad hoc regime for so-called stablecoins15 designed
to tackle specific risks, for instance, those stemming from the underlying technology,
as well as ‘traditional’ risks materializing in the new digital space. Regarding the latter,
MiCAR establishes safeguards to ensure the safe and sound management of the reserves
of underlying assets, as well as prevent ‘run risks’ in case issuers are unable to meet
redemption requests by token holders.
Despite progress, there are still unresolved issues. For instance, MiCAR’s entity-based
approach does not cover the entire DeFi ecosystem, where services are provided through
decentralized applications running on permissionless networks and using smart contracts,
with minimal or no intermediary involvement.16 On a broader scale, complications also
arise because, in a completely disintermediated environment, the relationships between
private parties are governed by algorithms, potentially eroding the role of laws and
contracts.17 This could lead to the emergence of new governance and risk management
issues. Additionally, the lines between the financial and payment sector and other
industries tend to be blurred in the digital space. EU regulatory institutions are currently
analysing these issues. It will be necessary to promote dialogue between authorities and
the market, even beyond the bounds of supervised operators, to intercept in advance
Communication from the Commission to the European Parliament, the Council, the European
Economic and Social Committee and the Committee of the Regions on a Digital Finance Strategy
for the EU (COM(2020) 591). Alongside this, the Commission adopted the Communication from the
Commission to the European Parliament, the Council, the European Economic and Social Committee
and the Committee of the Regions on a the Retail Payments Strategy for the EU which aims to enhance
Europe’s payment market (COM(2020) 592); this includes the promotion of instant payments, which
later led to the adoption in March 2024 of the Instant Payments Regulation (IPR).
Regulation (EU) 2022/858 of the European Parliament and of the Council on a pilot regime for market
infrastructures based on DLT.
MiCAR regulates three categories of crypto-assets: (i) asset-referenced tokens (ARTs); (ii) e-money
tokens (EMTs), both of which count as so-called stablecoins – crypto-assets that purport to maintain
a stable value by referencing other assets, although they differ in terms of the referenced assets and
the rights of the holders; and (iii) crypto-assets other than ARTs and EMTs, a residual category which
encompasses crypto-assets that are different from ARTs and EMTs.
On the issues that are beyond the scope of MiCAR, see P. Cipollone, ‘Conference on Digital Platforms
and Global Law’, keynote speech, Rome, 29 April 2022.
P. Cipollone, ‘Risposte (e proposte) della Banca d’Italia alle sfide dell’evoluzione tecnologica’, Rivista
del Diritto Bancario, 2022.
the development trends of the digital financial industry and try to guide them in safe and
efficient directions.18 I will also talk about this later.
On the other side of the Atlantic, the United States initially opted for enforcement actions
for specific crypto-asset offerings and platforms19 and, more recently, openly promoted
US leadership in digital assets and financial technology, including the future adoption
of a federal regulatory framework for the issuance and operation of digital assets.20 The
change in the US regulatory environment is evident as Congress is considering legislative
initiatives for stablecoins, including their use for payment.21
Regarding tax policy, several countries have adopted specific tax rules for crypto-assets
or have provided comprehensive administrative guidelines that extend to them the tax
rules for certain traditional assets. Tax reporting obligations have been imposed on
crypto-asset services providers, often leveraging regulatory frameworks, in order to avoid
crypto-asset transactions being used as a way to evade taxation. There are still issues
arising from the decentralized and anonymous nature of digital assets to be addressed.
The taxation of tokenized financial instruments also needs further development alongside
regulatory frameworks.
Identifying the scope of regulation and taxation: potential synergies
The second major challenge for both financial regulation and taxation in the new
digital world is the need to identify the scope of the rules, to ensure certainty, clarity
and consistency, thereby contributing to their effectiveness and making them simpler to
understand.
To this end, as in the traditional payment and financial sectors, regulation plays a crucial
role in defining the scope of applicability for the relevant products, services, individuals
and entities. While the ‘same activity, same risk, same regulation’ principle should
remain central, rules should address the specific features of emerging technologies.
The rule-making process should break down the various functions of each type of
digital asset, assess the associated risks, and understand the related income streams.
See European Banking Authority and European Securities and Markets Authority, Joint EBA-ESMA
Report on the recent developments in crypto-assets (Article 142 of MiCAR), 16 January 2025, for an
extensive analysis of DeFi and other activities not covered by MiCAR such as crypto lending and
borrowing. With regard the DLT pilot regime implementation, see ESMA, Letter to EU institutions on
DLT Pilot Regime Implementation, 3 April 2024; European Commission, Letter on the DLT Pilot Regime
Implementation, 3 May 2024.
This is particularly the case with the US Securities and Exchange Commission (SEC). See the list of the
crypto-assets and cyber enforcement actions kept by the SEC.
Strengthening American Leadership in Digital Financial Technology’, US Presidential Executive Order
issued on 23 January 2025.
See the Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 a.k.a. ‘GENIUS
Act of 2025’ and the Stablecoin Transparency and Accountability for a Better Ledger Economy Act of
2025, a.k.a. the ‘STABLE Act of 2025’.
In this context, regulation may provide a valuable anchor for the definition of tax rules for
digital assets. Some considerations may assist us in this task.
First, the civil law framework provides a baseline reference for the tax treatment of
digital assets. Countries have adopted different approaches depending on their broader
legal systems. For instance, crypto-assets have been defined in different ways across
jurisdictions – as a form of property, intangible assets, financial instruments, foreign
currencies, ’digital representations of value’ or even commodities.22
Second, identifying the functions, risks and income streams of digital assets and activities
within the regulatory framework may help ensure, on the one hand, that digital and
traditional assets with similar functions are treated the same way from a tax perspective.23
On the other hand, it can pinpoint the unique features of digital assets and activities that
need to be taken into account when establishing suitable tax rules.
Third, tax policymakers should be cautious about directly transposing regulatory
concepts into tax provisions. Financial regulation is often based on principles and goals
that do not immediately transfer to the tax system, which has its own logic and rules.24
Last but not least, with regard to taxation, once its scope is defined, it will be necessary
to assess whether the existing enforcement procedures are effective, or else to devise
entirely new solutions. Regulatory efforts to identify new market participants and
emerging business models may serve as a valuable reference for tax policymakers.
Many jurisdictions have already included regulated and supervised crypto-asset service
providers, such as exchange and trading platforms, within the scope of third-party ‘tax
agents’. Conversely, where digital transactions are fully decentralized,25 it may prove
very challenging to identify entities able to manage the tax obligations or act as ‘tax
reporting agents’; therefore, new enforcement systems need to be explored.
In light of these considerations, addressing the challenges of the digital era requires
a proactive, future-proof approach, taking account of potential synergies between the
different regulatory domains. Therefore, it is crucial to foster a constant dialogue with
traditional and new market participants in order to intercept and pivot technological and
market developments in financial and payment services within the digital landscape. This
dialogue can be a valuable source of knowledge about the digital finance ecosystem
to enable policymakers to chart the path forward towards a well-defined regulatory
As highlighted, among others, in OECD, Taxing Virtual Currencies: An Overview of Tax Treatments and
Emerging Tax Policy Issues, OECD Publishing, Paris, 2020.
For instance, e-money tokens denominated in foreign currencies, mostly used for payment purposes,
should receive the same tax treatment as fiat foreign currencies, whereas unbacked crypto-assets,
which can be held for other reasons, including investment and speculative intent, should be the object
of specific tax rules.
For instance, according to the ‘substance over form’ principle, some investment tokens that are seen
as financial instruments from a financial regulation standpoint might be characterized differently for
tax purposes.
Compared with the traditional account-based financial system, digital asset transactions carried out
on public DLTs adhere to a different paradigm, allowing visibility of transaction amounts and holdings
on the ledger, but not of identifiable owners.
scope and tailored and flexible rules. Along the same line, regulators, central banks and
supervisory authorities can serve as catalysts for innovation and actively contribute to
the development of new ideas, enhancing the efficiency and security of financial and
payment services. They are also innovation drivers themselves, notably when exploring
the potential of central bank digital currencies (CBDCs).26
Banca d’Italia is at the forefront of digital finance and payments, leveraging its roles as
a central bank, supervisory authority and innovation enabler. Together with the ECB and
other national central banks of the euro area, we, as Banca d’Italia, have been running
analyses in view of the possible introduction of a digital euro and have conducted
exploratory work on new technologies for wholesale central bank money settlement.
We participate in the Eurosystem PISA Framework,27 which also covers digital payment
tokens; we supervise crypto-asset issuers and service providers as the national competent
authority under MiCAR, together with Consob (Commissione Nazionale per la Società
e la Borsa), the Italian Companies and Stock Exchange Commission; we also offer an
integrated set of innovation facilitators designed to encourage dialogue with market
participants and support the development of FinTech projects (among others, Canale
Fintech and Milano Hub).28
The need for international cooperation and cross-sectoral coordination
The third challenge that I would like to raise today is related to the need for
international cooperation and cross-sectoral coordination efforts aimed at establishing,
implementing, and enforcing common minimum standards and rules. The borderless
nature of digital assets, in fact, makes it difficult to link them to a given jurisdiction
for regulatory, anti-money laundering (AML) and counter-financing of terrorism (CFT),
and tax purposes, opening the door to regulatory and tax arbitrage as well as other
unintended consequences.
In this regard, one issue to monitor is how the rapidly changing global landscape of
digital assets could impact the EU market and regulatory framework. It is critical for
EU central banks and supervisors to thoroughly assess the effectiveness of the new
digital asset regulation and to address potential risks, especially those arising from the
increasing interconnectedness and exposure of European financial intermediaries to
non-EU products and operators. It will also be essential for EU institutions to continue to
At the end of 2023, 94 per cent of central banks surveyed by the BIS were either exploring or
testing the issuance of a CBDC. See A. Di Iorio, A. Kosse and I. Mattei, ‘Embracing diversity,
advancing together – results of the 2023 BIS survey on central bank digital currencies and crypto’,
BIS Papers, 147, 2024.
Payment Instruments, Schemes and Arrangements. The PISA framework establishes a set of oversight
principles, based on international standards, to assess the safety and efficiency of electronic payment
instruments, schemes and arrangements (source: European Central Bank website).
C. Scotti, ‘Journey to the future of the financial system’, speech at the 31st ASSIOM FOREX Congress,
2025, p. 8.
advocate for the implementation of the standards for digital assets and new technologies
promoted by international organizations.29
In taxation, the OECD, under the auspices of the G20, has developed a new standard
for the automatic exchange of information on crypto-assets30 to prevent them from
becoming a new ’tax haven’. Many countries have committed to adopting this standard.
The EU has already implemented it with a forward-looking approach to the definition
of crypto-assets, which ensures that the scope can be expanded to include future asset
types.31
While these efforts are a major step towards extending tax compliance to digital assets,
some challenges still remain, particularly regarding their limited geographical coverage
and their applicability to decentralized transactions, which may create loopholes. Another
major challenge is the lack of international coordination in the tax treatment of digital
assets. Differences in countries’ approaches may affect the development of national
markets and lead to jurisdictional arbitrage. Additionally, the lack of global coordination
could result either in double taxation or in digital assets being untaxed altogether.32
The uneven implementation of AML/CFT rules for digital assets also poses concerns.
A widespread application of these rules is essential to leverage synergies with tax
compliance and reduce redundancies between the two frameworks.33 Despite the
introduction of specific standards by the Financial Action Task Force (FATF),34 significant
variation in their implementation and enforcement still exists. This creates opportunities
As regards crypto-assets and DeFi see: Committee on Payments and Market Infrastructures (CPMI)
and Board of the International Organization of Securities Commissions (IOSCO), Application of the
Principles for Financial Market Infrastructures to stablecoin arrangements, July 2022; Basel Committee on
Banking Supervision (BCBS), Prudential treatment of cryptoasset exposures, December 2022; FSB, Global
Regulatory Framework for Crypto-asset Activities, 17 July 2023; IOSCO, Policy Recommendations for
Crypto and Digital Asset Market, 16 November 2023; IOSCO, Policy Recommendations for Decentralized
Finance (DeFi), September 2023; Financial Action Task Force, Targeted Update on Implementation of the
FATF Standards on Virtual Assets and Virtual Asset Service Providers, FATF, Paris, 2024.
OECD, International Standards for Automatic Exchange of Information in Tax Matters. Crypto-Asset
Reporting Framework and 2023 update to the Common Reporting Standard, OECD Publishing, 2023.
The Crypto-Asset Reporting Standard (CARF) mirrors the Common Reporting Standard for financial
assets (CRS) and, like the latter, leverages AML KYC rules.
Directive (EU) 2023/2226 (DAC 8) on administrative cooperation in the field of taxation, adopted by
the Council of the European Union on 17 October 2023.
The need for multilateral and supranational solutions to the tax problems arising from the increasing
globalization and digitalization of the economy has long been at the forefront of the main international
fora and institutions, such as the G20, the G7, the OECD, the EU and, more recently, the UN. It has been
cited, among others, in E. Letta, Much More Than a Market, April 2024 (the ‘Letta Report’).
As also highlighted by the IMF in E. Mathias and A. Wardzynski, ‘Leveraging Anti-money Laundering
Measures to Improve Tax Compliance and Help Mobilize Domestic Revenues‘, IMF Working Paper,
21 April 2023. Tax crimes are one of the main predicate offences of money laundering in most countries.
On the role of the financial intelligence units (FIUs) in tackling serious tax crime, see the Bulletin of the
Egmont Group of FIUs, ‘Money Laundering of Serious Tax Crimes – Enhancing Financial Intelligence
Units’ Detection Capacities and Fostering Information Exchange‘, July 2020.
FATF Recommendation 15 and related Interpretative Note, regulating, inter alia, the supervision and
obligations of crypto-assets service providers (CASPs) – including Know Your Customer (KYC) rules and
the reporting of suspicious transactions to the FIUs – and the transparency of crypto-asset transfers
(‘travel rule’).
for regulatory arbitrage, undermines the global response against the illicit use of
digital assets, and jeopardizes cross-sectoral domestic coordination and international
cooperation. The launch of a new round of mutual evaluation by the FATF and its global
network will help exert further pressure on countries to strengthen their AML/CFT systems,
including for crypto-assets. In the EU, MiCAR and the Transfer of Funds Regulation (TFR)35
are aligned with FATF standards, and the new EU Anti-Money Laundering Authority
(AMLA) will improve supervision and cross-border cooperation.36
Importantly, AML/CFT and tax authorities face similar challenges nationally and
internationally, particularly due to the decentralization and a-territoriality of many digital
assets and payments. While these issues are being addressed within their respective
regulatory domains, effective cross-sectoral coordination is essential to maximize
synergies and face emerging risks.
Conclusions
Digital assets are reshaping the payment and financial industries, offering new
opportunities but also posing new risks or exacerbating traditional vulnerabilities.
In this rapidly evolving landscape, the development of new approaches to regulation
and taxation, alongside the traditional ones, is crucial to avoid undue constraints on
innovation while safeguarding financial stability and integrity, the proper functioning of
markets and payment systems, the protection of individuals’ rights, and the fulfilment
of tax obligations. Rules should be simple, fair, clear, consistent, and future-proof; they
should also exploit synergies across domains where possible.
Central banks and regulators play a key role in balancing innovation with secure, efficient
financial and payment services that support the economy, while providing a solid anchor
for tax systems. Banca d’Italia is committed to this mission, working within the EU’s new
frameworks for digital assets while encouraging innovation and ensuring the effectiveness
of new rules.37 Tax policymakers may contribute to designing a clear legal framework for
digital assets through straightforward rules that also maintain fairness with traditional
instruments.
This conference provides an opportunity to discuss these issues and emphasize the need
for rules fit for the digital age. I look forward to a productive and engaging discussion.
Regulation (EU) 2023/1113 of the European Parliament and of the Council on information accompanying
transfers of funds and certain crypto-assets.
AMLA will ensure coordinated and convergent supervisory actions on CASPs and will possibly directly
supervise those posing the highest risks. AMLA will also contribute to improving cooperation between FIUs
and support the development of joint analysis on suspicious cross-border cases, involving crypto-assets.
See instance, Banca d’Italia, ‘Regulation (EU) 2023/1114 on Markets in Crypto-assets (MiCAR)’,
Communication of 22 July 2024.
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