Staking as a Service (SaaS): Taxation for Stakers and Providers in Spain

Staking as a Service allows cryptocurrency holders (ETH, SOL, ADA, DOT...) to earn rewards without the need to technically manage a validation node. Instead, they hire an infrastructure provider that operates the node for them in exchange for a fee.

Main Staking as a Service Providers

For Individuals (Non-Custodial)

• Allnodes: Staking for Ethereum, Solana, Cardano, etc. The client retains the keys.
• Kiln: Geared towards institutions and professionals.
• P2P.org: Multi-chain, starting from $32 ETH (32 ETH minimum for a personal validator).
• Everstake: Multi-chain.

Custodial (Provider Controls the Keys)

• Coinbase Cloud (formerly Bison Trails).
• Binance Staking: Centralized.
• Custodial services involve higher counterparty risk.

The Difference Between Non-Custodial and Custodial

Taxation for the Staker (SaaS Client)

Staking Rewards

Whether non-custodial or custodial:

• Staking rewards (ETH, SOL, ADA...) result from active participation in consensus → classified as investment income.
• Value in EUR at the time the rewards are credited to your account (or wallet).
• If the provider distributes daily → each distribution is a taxable event on that date.

Provider Fees

The provider charges a percentage of your rewards as a service fee (e.g., Kiln charges 15% of your staking rewards for ETH).

Taxation of the Fee:

• Your net income = total rewards − provider fee.
• Is the fee deductible? You must declare the gross income from rewards and then account for the fee:
  • Option A: Declare the net income (rewards minus the fee). Simpler.
  • Option B: Declare the gross income and deduct the fee as an expense. More technically accurate.
• Without clear DGT criteria, Option A is pragmatically acceptable.

Acquisition Cost of the Initial Stake

The ETH/SOL/ADA deposited for staking:

• Does not constitute a transfer when deposited into the staking contract (you remain the owner).
• Upon withdrawal → it remains yours, plus rewards.
• Capital gains on the underlying asset (e.g., ETH rising from €2,000 to €4,000) are taxed when you sell the ETH (not when you stake or unlock it).

Taxation for SaaS Providers (Businesses)

If you operate a Staking as a Service business in Spain:

• Corporate Tax (IS): Fees received from clients are considered income from economic activity.
• VAT: Infrastructure services are subject to VAT (21%). If your clients are other EU companies → reverse charge mechanism applies.
• Custody of Third-Party Assets: If you manage PoW or staked assets for clients → you are subject to AMLFT (anti-money laundering and terrorist financing) obligations as a virtual asset service provider (VASP).

Slash: Loss Due to Validator Penalty

If your provider's node incurs slashing (protocol penalty for double signing or other errors):

• You lose part of your staked ETH.
• This loss is a capital loss: acquisition cost of the lost ETH − transfer value (0 as it is destroyed by the protocol) = loss.

Does the provider cover slashing losses? Some SaaS providers offer slashing guarantees:

• If they compensate you → the compensation = general taxable income (GPO).
• The loss of ETH → already realized capital loss.
• Net: it could be GPO-neutral if the compensation equals the loss.

Staking Withdrawal: The Unbonding Period

Many chains have an unbonding period (e.g., Ethereum: up to 3-4 days, Cardano: immediate, Polkadot: 28 days):

• During the unbonding period, there is no yield.
• The waiting time does not generate a taxable event.
• The asset remains yours with the same acquisition cost.

Liquid Staking vs. SaaS Non-Custodial: Key Differences

Updated: April 2026 | Fiscal Year: 2025