Introduction

Two parallel phenomena are reshaping the digital economy, with direct tax implications that tax authorities (TAs) in Latin America and the Caribbean (LAC) cannot ignore: the rise of cryptoassets and the expansion of digital platforms that facilitate the exchange of labor, goods, and services. Both generate massive taxable events[1]. Global crypto market capitalization closed the first quarter of 2026 at $2.4 trillion (Coin Gecko, 2026), and between July 2022 and June 2025, LAC recorded a cryptocurrency transaction volume of nearly $1.5 trillion, establishing itself as one of the most dynamic regions in the world (Chainalysis, 2025).

The obstacle is not regulatory: in most jurisdictions in Latin America and the Caribbean, the existing tax framework would be sufficient to tax these transactions. The problem lies in information and analytical capacity. The crypto ecosystem relies on a public, immutable blockchain architecture where every transaction is verifiable, yet it coexists with pseudo-anonymity. Digital platforms, on the other hand, are private environments where information is available only to the operator. In both scenarios, the challenge is the same: the information exists, but it does not flow to the authorities.

Cryptoassets: risk categories requiring tailored treatment

The first design flaw in the sector’s tax administration is treating cryptoassets as a homogeneous category. Their economic characteristics differ, and therefore their tax classifications do as well.

Criptocurrencies (Bitcoin, Ether): generate capital gains upon disposal. According to the digital asset reporting legislation passed in the U.S. in 2021, the Joint Committee on Taxation estimated that it would generate nearly $28 billion in additional revenue over a decade (Joint Committee on Taxation, 2021). Starting in the 2025 tax year, digital asset custodial brokers in the U.S. must report gross income to the IRS using Form 1099-DA, with a phased implementation that extends the reporting of taxable income to 2026 (IRS, 2024).

Stablecoins (USDT, USDC): deserve specific attention in Latin America and the Caribbean, where they account for more than half of all purchases on exchanges in Colombia, Argentina, and Brazil (Chainalysis, 2025). In March 2026, the FATF reported that stable coins accounted for 84% of illicit virtual asset volume in 2025, a figure produced by Chainalysis and included in the FATF report—with more than 250 stable coins in circulation and a market capitalization exceeding $300 billion (FATF, 2026).

Staking and mining: generate income upon receipt of the asset, valued at market price. This approach was adopted by the IRS (Revenue Ruling 2023-14), the UK’s HMRC (Cryptoassets Manual, updated in 2024), and Australia’s ATO (2024).

Decentralized finance (DeFi): This represents the largest regulatory gap. In June 2025, the FATF noted that most anti-money laundering frameworks applicable to virtual asset service providers do not extend to DeFi entities (FATF, 2025). In April 2025, the U.S. Congress repealed regulations that would have extended mandatory reporting to DeFi intermediaries (U.S. Congress, H.J.Res. 25, April 10, 2025), opening the door to regulatory arbitrage

.

Digital platforms: an equally urgent front

The technical instrument that changes the equation is the OECD’s Model Reporting Rules for Digital Platforms (MRDP) (2020). Under this framework, platforms must collect and report information on all their sellers—name, tax identification number, address, bank account, number of transactions, and total amount received—and automatically exchange this information across jurisdictions through the DPI MCAA.[2].

The European Union implemented the MRDP through the DAC7 Directive (Directive 2021/514/EU), which took effect on January 1, 2023, with the first reporting cycle completed in February 2024 (European Commission, 2021). Spain implemented it through Royal Decree 117/2024 and Order HAC/72/2024, which approved Form 238 for platform operators (AEAT, 2024). The United Kingdom, Canada, and Australia implemented equivalent rules as of January 2024.

In Latin America and the Caribbean (LAC), the adoption of the MRDP is still in its infancy. No country in the region has formally implemented it, creating a specific asymmetry: platforms report revenue from their European and Canadian sellers but do not do so for their Latin American sellers. This gap is also an opportunity: countries that adopt the MRDP will receive information about their residents operating on platforms in those jurisdictions.

CARF and MRDP: A Critical Milestone in 2027

For crypto-assets, the equivalent of the Common Reporting Standard (CRS) is the Crypto-Asset Reporting Framework (CARF). As of March 2026, 53 jurisdictions have signed the CARF-MCAA, including Colombia (October 31, 2024), Brazil (November 21, 2024), Chile (October 21, 2025), and Costa Rica (November 26, 2024). In total, 75 jurisdictions have made a political commitment to the framework: 52 with exchanges set to begin in 2027, and a second group by 2028—including Canada, Australia, Singapore, and the United Arab Emirates. The U.S. has declared its intention to begin exchanges in 2029, although it has not yet passed binding domestic legislation to that effect (OECD, 2025; OECD, 2026).

2027 is the year when the first massive flows of information will begin to reach the participating TAs. Governments that have not built-up analytical capacity by that time will receive data they will not know how to process. It should be noted that CARF has an explicit limitation: it does not cover self-custody wallets or DeFi protocols without an identifiable centralized operator. This boundary defines which information will be received through multilateral channels and which will require forensic techniques.

High-impact forensic technologies

The blockchain is public, immutable, and auditable in real time. Three forensic techniques, originally developed for criminal investigations, are directly applicable to tax audits: (i) address labeling, which links a blockchain address to a real-world entity; (ii) address clustering, which groups all addresses that co-signed multi-input transactions under a single subject; and (iii) chain analysis, which tracks the flow of funds transaction by transaction to a point of known identity. The latter formed the basis of the most emblematic case: in February 2022, the U.S. Department of Justice recovered $3.6 billion linked to the 2016 Bitfinex hack through blockchain traceability (U.S. Department of Justice, 2022).

The market offers established trading platforms: Chainalysis (used by the IRS, the DEA, and numerous law enforcement agencies in Europe and North America), TRMLabs (covering more than 100 blockchains and focusing on stable coins on the Tron network, the most widely used for USDT transactions in Latin America), and Elliptic (a UK-based company with a strong presence in the European financial and regulatory sectors). The World Bank and the IMF offer technical assistance programs that can finance access to these tools.

Comparative international experiences

Advanced tax administrations have achieved results by combining simple regulatory frameworks with technological tools. The U.S. classified cryptocurrencies as property in 2014 (IRS Notice 2014-21) and strengthened compliance through mandatory questions on Form 1040. Spain uses Form 721 for cryptoassets held abroad and Form 238 for digital platforms, supplemented by blockchain analytics tools. The United Kingdom published specific technical guidelines (HMRC, 2024) and uses blockchain analysis to detect non-compliance. Brazil implemented monthly reporting for exchanges through RFB Normative Instruction No. 1,888 of 2019 and, in 2025, made progress in aligning with the CARF (Brazilian Federal Revenue Service, 2019).
The United Nations Toolkit for Assessing Tax Risks Related to Crypto-Assets, adopted at the 30th Session of the Committee of Experts (March 2025) and published in October 2025, provides a structured framework of questionnaires by risk type—tax evasion, losses and deductions, functional substitutes—designed specifically for administrations with limited resources (UN Tax Committee, 2025). It is the tool best suited to the LAC context available to date.

The window of opportunity is now

The convergence of CARF-MCAA and MRDP—with the first large-scale data exchange scheduled for 2027—the sustained growth of the digital economy in Latin America and the Caribbean, and the maturity of blockchain analysis tools present a unique window of opportunity for tax authorities in the region. The challenge is to build analytical capacity now: prioritize risks in cryptoassets—especially stablecoins and DeFi—implement reporting frameworks for digital platforms and establish systematic cross-checks with tax returns. Administrations that act today will be prepared to process the information that will come; those that wait will continue to lose revenue to taxpayers operating without effective oversight. The tax gap is not one of legislation, but of information and capacity—and the tools to close it are already available.

References:

• • Agencia Estatal de Administración Tributaria (AEAT). (2024). Modelo 238: Declaración informativa para la comunicación de información por parte de operadores de plataformas. Ministerio de Hacienda.
• • (2025). 2025 Geography of Cryptocurrency Report / 2025 Global Crypto Adoption Index.
• • Coin Gecko. (2026, April 16l). 2026 Q1 Crypto Industry Report.
• • European Commission. (2021). Council Directive 2021/514/EU (DAC7).
• • Financial Action Task Force (FATF). (2025, June 26). Targeted update on implementation of the FATF standards on virtual assets and virtual asset service providers. FATF/GAFI.
• • Financial Action Task Force (FATF). (2026, March 3). Targeted report on stablecoins and un-hosted wallets – Peer-to-peer transactions. FATF/GAFI.
• • Her Majesty’s Revenue & Customs (HMRC). (2024). Cryptoassets manual. HM Revenue & Customs.
• • Internal Revenue Service (IRS). (2014). Notice 2014-21: IRS virtual currency guidance. U.S. Department of the Treasury.
• • Internal Revenue Service (IRS). (2023). Revenue Ruling 2023-14: Taxability of staking income. U.S. Department of the Treasury.
• • Internal Revenue Service (IRS). (2024). Final regulations and related IRS guidance for reporting by brokers on sales and exchanges of digital assets.
• • Joint Committee on Taxation. (2021). Estimated revenue effects of the revenue provisions contained in the “Infrastructure Investment and Jobs Act.” U.S. Congress.
• • Organization for Economic Co-operation and Development (OCDE). (2020). Model Reporting Rules for Digital Platforms (MRDP).
• • Organization for Economic Co-operation and Development (OCDE). (2025, November). Crypto-Asset Reporting Framework: 2025 monitoring and implementation update. Global Forum on Transparency and Exchange of Information for Tax Purposes.
• • Organization for Economic Co-operation and Development (OCDE). (2026, March 3 ). CARF-MCAA signatories.
• • Receita Federal do Brasil. (2019). Instrução Normativa RFB n.º 1.888, de 3 de maio de 2019.
• • TRM Labs. (2025). August 2025 product highlights: Expanded coverage and smarter workflows.
• • UN Committee of Experts on International Cooperation in Tax Matters (UN Tax Committee). (2025). Toolkit for the evaluation of crypto tax risks (approved at the la 30^th Session, March 2025; Published in October 2025). United Nations, DESA.
• • S. Congress. (2025, April 10). H.J. Res. 25: Joint resolution providing for congressional disapproval of the rule submitted by the Internal Revenue Service relating to “Gross Proceeds Reporting by Brokers That Regularly Provide Services Effectuating Digital Asset Sales.”
• • U.S. Department of Justice. (2022, February 8 ). Two arrested for alleged conspiracy to launder $4.5 billion in stolen cryptocurrency.

[1] In this regard, it is worth noting that at the Tax Administrators’ Meeting held in Montevideo in October 2025—sponsored by Spanish Cooperation, Uruguay’s General Directorate of Taxation (DGI), and CIAT—the most significant challenges identified were legislation and management of cryptoassets, as well as legislation and oversight of digital services provided by non-residents.

[2] 22 jurisdicciones firmaron en Sevilla (nov. 2022) el DPI MCAA para el intercambio automático de información sobre ingresos de plataformas (de la Región participaron Argentina, Colombia y Costa Rica).