CARF reporting follows your users' tax residence, not your headquarters. Here's how to work out where you're on the hook, and for whom.
The first question every CASP asks about CARF is "do we even have to report?" The honest answer is that it depends less on where you're incorporated than on where your users live, and that catches a lot of teams off guard.
To the jurisdictions where its reportable users are tax-resident, not where the provider is based. Residence is established through the user's self-certification collected at onboarding.
Often yes. DAC8 reaches any crypto-asset service provider with EU-resident users, regardless of where the provider is established. Serving European customers can bring you into scope without an EU entity.
No. In the EU you register in one member state and report there for all EU-resident users, and the OECD Common Transmission System distributes a filing to every jurisdiction a user is resident in. You file once and it reaches the relevant authorities.
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CARF is built around the tax residence of the user, not the location of the platform. A reportable user is reported to the jurisdiction where they're resident, which is why the self-certification you collect at onboarding is the foundation of the whole regime. Get residence wrong and you report the right user to the wrong country.
In the EU, DAC8 lets you register in a single member state and report there for all your EU-resident users; that state then shares the data with the others. Under the wider OECD network, filings flow through the Common Transmission System so a single submission reaches every jurisdiction a user is resident in. You file in one place, but you're effectively reporting to many.
This is the part that surprises non-EU providers: DAC8 reaches any CASP with EU-resident users, wherever the provider sits. Serving European customers can pull you into scope even without a European entity. The same logic runs across the OECD's participating jurisdictions as they switch on.
The practical challenge is resolving, per user, which jurisdictions they're reportable to, then filing each authority's format without double-reporting anyone. That's what our CARF and DAC8 reporting platform does: it determines nexus from the validated residence data and routes each user to the right filing. If a user won't certify their residence, the 60-day rule governs what happens next. The OECD exchange-of-information hub sets out the framework.