Bitvavo checks customers’ tax information: what does this mean for US persons?

Bitvavo is asking existing customers to check their nationality and tax information. For US persons living in the Netherlands, this can be confusing because tax residence and US tax obligations are not the same. Answer the questions truthfully, but first check which status Bitvavo is asking you to provide.

Why is Bitvavo asking for tax information now?

Bitvavo is a Dutch crypto exchange where customers can buy, sell and hold bitcoin and other crypto assets. The platform is supplementing the information it holds about existing and new customers because of new European rules.

The main rule concerning tax information is DAC8. This directive extends the automatic exchange of information to crypto assets. Since 1 January 2026, crypto platforms have been collecting information about customers and reportable transactions. The first reporting will take place in 2027.

Bitvavo asks for information including your nationality, place of birth, tax identification number and the country or countries where you are liable for tax. By around the first reporting cycle, existing individual customers must have provided a self-certification that establishes their tax residence or tax residences.

Other crypto exchanges are asking these questions too

Crypto platforms are actively reviewing their existing customer records and contacting customers to supplement their tax information. Bitvavo is not the only platform doing this. Coinbase, Bitpanda, Kraken, Crypto.com and bitFlyer Europe also ask for tax residences and tax identification numbers because of DAC8 or the international Crypto-Asset Reporting Framework.

The exact questions, deadlines and consequences differ between platforms. The fact that these exchanges collect tax information does not mean they all apply the same policy to US persons at the same time.

Tax residence is not the same as being a US person

Unfortunately, many questions asked by Bitvavo and other financial institutions are fundamentally worded incorrectly. This can cause a customer to give the wrong answer or overlook the information icon. Both the financial institution, Bitvavo in this example, and the customer can be affected. Information may be reported to the wrong country. The customer may then face questions from tax authorities or a blocked account, while the institution may face incorrect reports, remediation costs and the risk of fines.

Tax residence is where most of the confusion arises. In its information, Bitvavo uses different terms such as “tax resident”, “paying tax” and “US person”. These terms do not mean the same thing:

• Tax residence: the country in which you are considered a resident under tax law. This generally depends on where you actually live and where the centre of your life is located, such as your home, family and work. You may be a tax resident of more than one country. A tax treaty then determines which country has priority. Please note that the United States taxes on the basis of citizenship. As a US citizen, you must therefore always file a US tax return, even if your tax residence is in another country.
• Paying US tax: a US tax payment obligation may also arise if you live in the Netherlands and, for example, trade with the United States. However, you can also have a tax obligation without having to pay tax.
• US person: this is a US tax term. For individuals, it includes US citizens and US resident aliens, among others.

You can live in the Netherlands and be a tax resident here while also having a US tax filing or information-reporting obligation. This does not automatically mean that you also have to pay US tax.

A question such as “Are you a tax resident of another country?” or “Do you pay tax in the US?” is therefore not automatically the same as “Are you a US person?” Look carefully at the question the screen actually asks. Ask Bitvavo for clarification if the form does not clearly distinguish between these situations.

Are you unsure whether you are a US person?

A valid US passport is not the only indication. Birth in the United States, US citizenship acquired through a parent, a green card or a long period of residence in the US may also be relevant.

The free US Person check from Americans Overseas gives you an initial indication in approximately two minutes. You can also read the explanations about being born in the US and US person status and about US tax obligations while living in the Netherlands.

The test helps you identify the right follow-up questions. Have your circumstances assessed personally if your nationality, green card status or history of residence is unclear.

What should you enter?

Bitvavo asks customers to confirm through a self-certification that their tax information is correct and complete. Do not guess or select an answer automatically. It is important to provide the correct answer.

• Check whether the question concerns nationality, tax residence, tax liability or US person status.
• Determine whether you are a US citizen, a green card holder or a US resident alien for another reason.
• Enter your Dutch information and BSN correctly if the Netherlands is your country of tax residence.
• Ask Bitvavo in writing how you should record a US tax connection on the relevant screen.
• Keep Bitvavo’s response and a copy or screenshot of your self-certification.

An answer given in a platform form does not determine whether you have a tax obligation under US law. Conversely, a possible US obligation does not disappear because the form fails to represent your situation clearly. You can find more background about reporting by financial institutions in the explanation of FATCA.

What are the consequences for US persons?

The consequences fall into three categories:

• US tax return: your status may mean that you have to file a US tax return or additional information forms. This does not automatically mean that you have additional tax to pay.
• Information reporting: Bitvavo reports information covered by DAC8 to the Dutch Tax and Customs Administration. DAC8 and FATCA are different regimes. Bitvavo’s public information does not indicate that reporting a US tax connection automatically means that all account information is sent directly to the IRS.
• Access to Bitvavo: missing tax information may lead to restrictions on your account. According to Bitvavo, you may then be unable to deposit, trade or withdraw until the information is complete.

One important question remains unanswered. Bitvavo does not publish a general policy explaining what happens when an existing customer provides all the requested information and confirms that they are a US person. It is therefore unclear whether such confirmation affects the customer’s ability to retain or use the account.

DAC8 is not a new crypto tax

DAC8 is a reporting rule, not a separate tax on crypto. The directive ensures that customer information and information about relevant crypto transactions reach tax authorities and can be exchanged between countries.

The filing, reporting and tax rules that apply to you depend on your personal circumstances. Filing a return, reporting information and paying tax are three different things.

Get Informed with Americans Overseas

We, the founders of Americans Overseas, were born in the Netherlands and received our American citizenship through our (American) mother.

When we first learned about the U.S.–Netherlands tax treaty around 2013, we felt disbelief (“this can’t be true”), anger (“how can they do this?”), fear (“will I get fined or have problems?”), and panic (“what should I do?”).

Unfortunately, it is true that there is a U.S. tax obligation for Dutch citizens who acquired American nationality by birth. There was no information from local authorities, the U.S. consulate referred us to the IRS, and the IRS itself was impenetrable.

That is why we started this initiative: to help others with reliable information, to prevent unnecessary panic, and to offer free, no‑obligation assistance. When needed, we can connect you with a network of affordable professionals (accountants) who can help you meet your U.S. tax obligations.

Contact us for more information

Sources

• Bitvavo: Why do we ask for your nationality, identification number and tax information?
• Bitvavo: Who is considered a US person for FATCA purposes?
• EUR-Lex: Council Directive (EU) 2023/2226, DAC8
• European Commission: DAC8
• IRS: US citizens and residents abroad, filing requirements
• IRS: Instructions for the Requester of Form W-9
• Coinbase: Tax information for non-US customers
• Bitpanda: How to find your TIN
• Kraken: Crypto-Asset Reporting Framework FAQs
• Crypto.com: Crypto-Asset Reporting Framework FAQs
• bitFlyer Europe: Tax residence outside the EU/EEA