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Compound Finance and COMP: DeFi loans without KYC and taxation in Spain

Compound is one of the oldest DeFi lending protocols. How interest in cTokens, the implicit accumulation of APY and rewards in COMP are taxed according to Spanish regulations.

Equipo declaracrypto·April 25, 2026·6 min read

Compound Finance: taxation of cTokens and COMP in Spain

Compound Finance is a decentralized lending (DeFi) protocol where users can deposit assets to earn interest or borrow using collateral. Unlike Aave, Compound uses a “cToken” model that represents the deposited position plus accrued interest.

The cToken model: implicit interest

When you deposit DAI in Compound you receive cDAI:

  • cDAI is not 1:1 with DAI: its value in DAI grows continuously.
  • If you deposit 1,000 DAI and the exchange rate is 0.02, you receive 50,000 cDAI.
  • Over time, the exchange rate rises to 0.022 → your 50,000 cDAI is worth 1,100 DAI (100 DAI interest).

There is no periodic token distribution: performance is embedded in the cToken/Token exchange rate.

cToken taxation: interpretative options

There are two interpretations:

Option A: Taxation upon withdrawal (event carried out)

  • While you have cDAI, there is no income: the exchange rate goes up but you receive nothing.
  • When redeeming cDAI → DAI: the difference between the DAI received and the DAI deposited = return on capital.
  • This option is favorable for the taxpayer (deferral).

Option B: Periodic taxation by accumulation

  • If the AEAT equates cDAI to a zero-coupon bond (implicit yield), it could require paying taxes on the accumulated interest period by period.
  • This option would be comparable to accumulation funds.

Recommendation: Option A is the most reasonable by analogy with the treatment of credits with implicit interest (you do not pay taxes until you collect). Without DGT criteria, document the position adopted.

COMP: the governance token

Compound automatically distributes COMP to lenders and borrowers:

  • Lender: you earn COMP in addition to the cToken APY.
  • Borrower: You also earn COMP (incentive to borrow).

Taxation of COMP received:

  • It is a return derived from the possession/use of the protocol → movable capital.
  • Value in EUR at the time of receipt of the COMP.
  • If the COMP is distributed continuously → you can make periodic claims and record each date.

Compound III (Comet): the new model

In 2022, Compound released Compound III (Comet), which simplifies the model:

  • Only one base asset (USDC) can be deposited to earn interest.
  • The other assets are collateral only.
  • COMP rewards continue to work the same.

Fiscal: Similar to the previous model but without cTokens; Interest in USDC can be distributed directly or accumulated in the account.

Loans in Compound: the borrower's side

If you borrow ETH by depositing USDC as collateral:

  • The ETH received as a loan is not income: it is debt.
  • Interest paid → possibly deductible if ETH is used for investment.
  • If the borrowed ETH is sold → transmission of ETH with profit/loss.

If your collateral is liquidated (you do not maintain the ratio):

  • Transmission of collateral at the liquidation market price → profit/loss.

Special cases

Compound + DeFi self-liquidating bots

If a bot kills you before you can act:

  • Liquidation is also a taxable event: transfer of collateral.

Reuse of cTokens in other protocols (Yearn, etc.)

  • If you use cDAI as collateral in another protocol → there is no transmission (the asset remains yours).
  • When liquidating that position in the other protocol → cDAI transmission.

Compound tax summary

EventTax treatment
Deposit in Compound (receive cToken)Possible transfer of assets
Accumulation of interest in cTokenNo income until rescued (Option A)
Redemption cToken → base assetMovable capital for accumulated interest
Receive COMP as a rewardMovable capital (value upon receipt)
Sell ​​COMPCapital gain/loss
Collateral LiquidationTransfer of collateral at liquidation price

Updated: April 2026 | Fiscal year: 2025

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