Maker/DAI: how vaults, DAI savings and the migration to Sky are taxed

MakerDAO is one of the oldest DeFi protocols. It allows you to mint DAI (a decentralized stablecoin) by depositing collateral (ETH, WBTC, stETH, USDC, etc.) in what is called a CDP/Vault. In 2024-2025, MakerDAO rebranded as Sky Protocol and launched USDS, the new version of DAI.

Maker's vault: is it a loan?

When you open a vault in Maker:

1. You deposit ETH (collateral).
2. Mint borrowed DAI (up to 67% of the collateral maximum, depending on the type of vault).
3. You pay a stability fee (annual interest rate) to return the DAI.

From the Spanish tax point of view:

• Depositing ETH into the vault is not a transfer (the ETH remains yours; if the vault is liquidated, the collateral is transferred at that time).
• The minted DAI is not income in itself: it is debt.
• The stability fee that you pay when returning → is it a deductible expense?

Stability fee: deductible expense?

• If you use the DAI for investments (buying other cryptocurrencies), the stability fee could be considered a financial expense of the investment.
• Without official AEAT criteria, deductibility is uncertain.

Vault Liquidations

If the price of ETH falls and you exceed the maximum collateralization ratio, your vault is liquidated:

• The protocol sells your ETH to cover the DAI debt + a penalty fee.
• Tax event: transmission of ETH at the market price at the time of settlement.
• If you had ETH purchased at a lower price → capital gain on the liquidated ETH.
• ETH collateral disappears, you reduce your debt position.

DAI Savings Rate (DSR) / Sky Savings Rate (SSR)

The DSR allows DAI to be deposited into the Maker contract to earn interest paid on DAI. On Sky, the equivalent is depositing USDS to earn additional SKY tokens and USDS.

DSR taxation:

• The DAI that you receive as interest from the DSR is a return on capital.
• Base: market value at the time of receipt (normally $1 DAI = $1 USD at the exchange rate of the day).

DAI → USDS migration

In 2024, MakerDAO migrated to Sky. DAI can be converted to USDS (new stablecoin) at a 1:1 ratio.

Is this a transmission?

• DAI → USDS: If they are different assets (different ticker, different contract) → DAI transmission.
• Both are worth $1 → in practice, profit/loss ≈ 0.
• However, if the DAI had an acquisition cost < $1 → small profit.

MKR/SKY Token: Governance

MKR is Maker's governance token. SKY is the Sky Protocol token.

• Receive MKR/SKY as a reward → return on capital or capital gain (general basis).
• Sell MKR/SKY → capital gain/loss.

Risk and collateralization ratio management

Users often add collateral continuously to avoid liquidations. Each setting:

• Additional ETH deposit → no transmission (remains yours).
• Partial withdrawal of minted DAI → no income.
• Withdrawal of ETH from the vault (partial) → no transmission (you still own it).

Summary table of tax events

Updated: April 2026 | Fiscal year: 2025