Outside the US: What MiCA, DAC8, UK CARF, and SG GST Mean for Your Crypto Receipts in 2026

A SaaS founder I work with runs his company from Austin, sells to customers in 40 countries, and accepts USDC and USDT through a non-custodial gateway. When I asked how he handles international tax and reporting on the crypto receipts, he said: “I figured if I got the US right, the rest would follow.”

It doesn’t. The US framework — Notice 2014-21, Form 1099-DA, the Schedule C path I covered in a companion post — applies to your US tax obligations. Every other jurisdiction has built its own approach, often with sharply different definitions of what crypto even is for tax purposes. If you sell into the EU, UK, Singapore, or Australia at any meaningful volume, you need to know what’s on the radar.

This post is a survey, not a deep dive. The goal is to give you five questions to ask your local tax advisor in each jurisdiction, the headline rules effective in 2026, and the regulatory regimes that have moved out of “future plan” into “now binding.” Treat it as even less of legal advice than the US-focused posts in this series. Local guidance varies. Enforcement varies more. Treaty interactions are their own swamp. Use this as a map, not a destination.

European Union: MiCA and DAC8 both bite in 2026

Two regimes matter for cross-border merchants selling into the EU.

MiCA — Markets in Crypto-Assets Regulation. MiCA regulates issuers of crypto-assets and crypto-asset service providers (CASPs) operating in the EU. For most stablecoins, MiCA imposes reserve requirements, redemption rights, capital adequacy, and supervision by EU national authorities. The MiCA transitional period ends July 1, 2026. After that date, entities providing crypto-asset services in the EU without MiCA authorization cannot rely on transitional arrangements.

What this means for a merchant accepting crypto from EU customers:

• You, the merchant, are not a CASP. You’re a counterparty. MiCA does not regulate you directly.
• Your gateway, if it offers crypto-asset services within the EU, needs MiCA authorization (or a member state’s transitional regime, which is about to expire). Before relying on a gateway for EU-bound payments after July 1, 2026, confirm its MiCA status with the gateway directly.
• Stablecoins issued by non-EU issuers face transaction caps under MiCA: 1 million transactions daily and €200 million in payment value daily for non-euro-denominated stablecoins used as means of exchange in payment for goods/services within the EU. For most individual merchants this won’t bind. At platform-aggregate level it has already drawn pushback.

If your gateway loses or never obtains MiCA authorization, your EU-facing crypto checkout is at risk. Verify before counting on it.

DAC8 — Eighth Directive on Administrative Cooperation. DAC8 entered into force January 1, 2026, and puts crypto-asset reporting obligations on CASPs that have customers in the EU. Reporting CASPs have to collect transaction data including user tax identification numbers and file annual reports to EU tax authorities. The first reporting year is 2026; reports must be filed between January 1 and September 30, 2027.

What this means for a merchant:

• If your gateway is a reporting CASP under DAC8 (most regulated EU-facing gateways will be), it may collect data on your EU customers’ transactions and report them to the customer’s national tax authority.
• If you operate through a non-EU gateway that nonetheless has EU customers, the reporting obligation may extend to that gateway under DAC8’s extraterritorial scope.
• You as the merchant aren’t the reporter. But your customers may get tax authority inquiries about transactions that show up in DAC8 reports. Document your receipts well, so if a customer’s tax authority asks them about a payment, the customer can match it to a purchase from you.

EU VAT on crypto payments. The Court of Justice of the European Union held in Skatteverket v. Hedqvist (C-264/14) that the exchange of traditional currency for Bitcoin (and vice versa) is a supply of services exempt from VAT under the EU VAT Directive. That ruling applies to the exchange itself. For a merchant accepting crypto in payment for taxable goods or services, the underlying supply is still VATable on the consideration received, measured at FMV. The crypto-for-currency exchange is exempt; the merchant’s underlying sale is not.

Member state implementations of Hedqvist and the follow-on crypto-VAT guidance vary. Germany, France, Sweden, and the Netherlands all have national guidance worth checking. Don’t assume one country’s treatment carries to another.

United Kingdom: HMRC’s approach and the CARF horizon

The UK isn’t in MiCA or DAC8 anymore (Brexit), but has its own evolving framework.

HMRC treats crypto as a chargeable asset. Receipt of crypto as payment for goods or services is trading income, recognized at fair market value at receipt, expressed in GBP. Any subsequent disposition is a capital event (capital gain or loss), unless the activity rises to the level of a trade in crypto-assets, in which case dispositions are also trading income. That line is fact-specific. HMRC’s Cryptoassets Manual is the primary reference document.

For a merchant accepting crypto from UK customers:

• UK VAT applies to the underlying sale, calculated on GBP-equivalent value of the crypto received at the time of supply.
• If you have a UK establishment for VAT purposes (UK-incorporated entity, UK warehouse, UK-based digital service provision under place-of-supply rules), crypto-paying customers count the same as any other customers for VAT registration and filing analysis.
• If you are not established in the UK, do not assume the normal UK VAT threshold protects you. HMRC’s non-established taxable person rules can require registration for taxable UK supplies of any value, subject to place-of-supply, reverse-charge, import, marketplace, and OSS/IOSS exceptions.
• Trading income from crypto receipts is part of your normal corporation tax computation if you have UK corporation tax exposure, or self-assessment income tax if you’re a sole trader.

CARF — Crypto-Asset Reporting Framework. The UK has committed to implementing the OECD’s Crypto-Asset Reporting Framework. UK-resident reporting crypto-asset service providers will be required to collect and report user information starting with the 2026 calendar year, with first reports due in 2027. Like DAC8, this is a CASP-side obligation, not a merchant-side one. The practical effect is that UK customers’ crypto activity becomes increasingly visible to HMRC.

Singapore: GST on the underlying supply, with a stablecoin caveat

Singapore’s tax treatment of crypto is unusually clear because IRAS issued a specific e-Tax Guide on Digital Payment Tokens (DPTs) several years ago and has updated it since.

The headline rules from IRAS’s Digital Payment Tokens guidance:

• A DPT must meet IRAS’s definition, including that it is not denominated in any currency and is not pegged by its issuer to any currency. IRAS examples include Bitcoin and Ether. Don’t assume fiat-pegged stablecoins such as USDC and USDT fall into the DPT category without checking current IRAS treatment and the token’s exact legal rights.
• The use of a qualifying DPT as payment for goods or services is not a supply by the payer — so the customer’s act of paying you in that DPT is not a separate taxable supply on the customer’s side.
• The underlying supply of goods or services by the merchant is taxable as normal. You charge GST on the Singapore-dollar-equivalent value at the time of supply (currently 9% GST as of 2026).
• Exchange of one qualifying DPT for another qualifying DPT is GST-exempt. Exchange of a qualifying DPT for fiat is generally also exempt under the DPT framework.

For a merchant accepting crypto from Singapore customers:

• If you’re not GST-registered in Singapore and not required to register, the customer’s use of a qualifying DPT does not by itself create output GST on the payment token. The registration question still turns on your Singapore-customer sales and the applicable domestic or overseas vendor rules.
• If you exceed the threshold for Overseas Vendor Registration under Singapore’s regime for digital services, the threshold calculation includes your Singapore-customer sales regardless of payment method. Crypto-paying customers count.
• The DPT framework gives a cleaner Singapore answer than most jurisdictions provide for tokens that qualify as DPTs. Stablecoin treatment deserves a separate check before you build a GST policy around it.

Australia: ATO’s CGT-and-revenue split

The Australian Tax Office treats crypto-assets as CGT assets by default, with the asset’s tax treatment driven by the purpose for which it’s held.

For a merchant:

• Crypto received as payment for goods or services in the course of carrying on a business is ordinary income, recognized at fair market value at the time of receipt, in Australian dollars.
• The crypto then sits as trading stock or as a CGT asset depending on the merchant’s intent and the nature of the holding period. For most merchants converting promptly to AUD or stablecoins, the post-receipt holding is short-term and treated as trading stock or current asset.
• GST applies to the underlying supply on its AUD-equivalent value at the time of supply if you’re GST-registered.
• Subsequent disposition of the crypto is a CGT event if held as a CGT asset, or trading income if held as trading stock. The classification matters because CGT discount rates and trading-income rates differ materially.

Australia hasn’t yet implemented an OECD CARF equivalent on the timeline the EU and UK are on. But the ATO has stepped up data-matching with Australian exchanges, and visibility is heading one direction only.

The pattern across jurisdictions

Step back, and four themes recur in every developed-market tax framework for crypto-accepting merchants:

1. Receipt = income at FMV in local currency. Universal. The FMV moment and the price source may differ, but the principle is the same in every jurisdiction examined here.
2. Subsequent disposition = gain or loss event, calculated against the FMV at receipt as basis. Universal. Capital vs. ordinary characterization varies.
3. Underlying VAT/GST applies on the supply, not on the crypto-for-fiat conversion. EU (Hedqvist), UK, Singapore, Australia all reach the same conclusion via different routes.
4. CASP-level reporting to tax authorities is becoming universal. DAC8 (EU), CARF (UK and OECD jurisdictions), 1099-DA expansion (US). Every developed market is moving toward broker / CASP reporting of crypto transactions to tax authorities. The merchant is rarely the reporter, but the merchant’s customer is increasingly visible to their own tax authority.

The five questions to bring to your local tax advisor in any jurisdiction where you sell at scale:

1. How is crypto received as payment characterized for income/profits tax purposes — trading income, capital, both?
2. What is the FMV moment and acceptable price source for translating crypto receipts into local currency?
3. Does VAT/GST apply to the underlying supply when paid in crypto, and is there any nuance from the crypto-for-fiat exchange exemption that affects my filings?
4. What CASP-side reporting (DAC8, CARF, local equivalent) might surface my customers’ transactions to the tax authority, and what should I document to support customer inquiries?
5. Does the gateway I use have local regulatory authorization (MiCA, FCA registration, MAS license, AUSTRAC registration) sufficient to serve my customers in this jurisdiction?

What to verify before adding a new jurisdiction

If you’re adding crypto checkout for customers in a jurisdiction you haven’t operated in before, the pre-flight checklist:

• Is your gateway authorized to provide crypto-asset services in this jurisdiction? Some non-EU gateways now restrict EU customer onboarding post-MiCA transitional period; confirm what your gateway’s coverage actually is. For Aurpay specifically, verify its MiCA status if you’re routing EU customer payments through it.
• What’s the local VAT/GST registration threshold for non-resident sellers, and do your crypto-paying customers count toward it?
• What’s the local recordkeeping standard for digital-asset receipts? Some jurisdictions require records in specific formats or retention periods longer than the US default.
• If your gateway issues invoices or receipts to customers, do those documents satisfy the local jurisdiction’s invoice content requirements (VAT number, exchange rate, jurisdiction-specific tax info)?
• Is there local CASP reporting that will eventually result in your customers being asked about transactions with you? Have you preserved enough metadata that you could match a payment to a customer order if asked years later?

The honest caveat

I want to repeat what I said in the opening: this is a survey. Every jurisdiction here has dedicated practitioners who have spent careers on the specific rules. If you’re operating at scale into the EU, UK, Singapore, or Australia, the right move is to retain a local tax advisor who handles crypto-accepting businesses in that jurisdiction. The cost is low relative to the cost of getting it wrong in an audit two years later, when the records you’d need to defend a position are stale or missing.

What this post can do is help you walk in with the right questions. Getting the answers is the advisor’s job.

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This article is general information for merchants and finance leads. It is not tax, legal, regulatory, or accounting advice for any jurisdiction, and does not establish a client relationship. Tax and regulatory treatment of crypto-asset transactions varies significantly by jurisdiction, by entity type, by transaction structure, and by date — and changes frequently. Every jurisdiction-specific point in this article should be verified against current local guidance before being relied on. Consult licensed tax, legal, and regulatory advisors in each jurisdiction where you operate.