Tokenization of real assets (RWA): taxation in Spain

Tokenized Real World Assets (RWA) represent real-world physical assets on blockchain. Real estate, government bonds, raw materials, works of art, commercial invoices... Everything can be tokenized. But tokenization creates new tax questions that Spanish regulations have barely addressed.

What is a tokenized RWA?

A tokenized RWA is a digital token that represents ownership (full or fractional) of a real asset:

• Properties: Token that represents a fraction of an apartment building.
• Bonds: State or corporate bond issued on-chain.
• Commodities: Token backed by physical gold (such as PAXG, XAUT).
• Art: Fraction of a digital or physical work of art.
• Invoices: Tokenization of invoices for business financing.

Main RWA platforms

• Centrifuge: Tokenization of invoices and credit assets.
• Ondo Finance: Tokenized American Treasury Bonds (USDY, OUSG).
• Backed Finance: ETFs and tokenized stocks.
• RealT: Tokenized real estate property (mainly US).
• Landshare: Real estate on blockchain.

Taxation of Gold Tokens (PAXG, XAUT)

Gold tokens such as PAXG (Paxos Gold) and XAUT (Tether Gold) represent troy ounces of physical gold stored in security vaults.

Tax treatment: Gold is "personal property" (even if it is virtuous). The PAXG/XAUT transmission is taxed as:

• Equity gain/loss: Sales price − acquisition cost, based on savings.
• The rate is the same as for cryptocurrencies.

Are they cryptocurrencies or are they gold? The DGT has not commented specifically. The most logical criterion is to treat them as the underlying asset (gold), but applying the same regime as for cryptocurrencies given their digital nature.

Real Estate Tokens: Yields and ITP

If you have tokens that represent participation in real estate:

• Income generated (rents): Return on real estate capital (or capital sometimes, depending on the structure).
• Sale of the token: Capital gain/loss. Savings or general basis? It depends on the holding period (more than 1 year → savings).
• ITP: When purchasing real estate tokens, would the Property Transfer Tax apply? The answer is still not clear, but if the legal structure is shares/participations (not direct transfer of the property), probably not.

Tokenized Bonds (USDY, Ondo OUSG)

American Treasury bonds tokenized as USDY (Ondo US Dollar Yield) offer bond yields:

• Daily returns: As return on movable capital → savings base, 19-28%.
• Transmission of the token: Capital gain/loss (difference between sale price and cost).
• They are income from a foreign source → the Double Taxation Agreement with the US must be applied if applicable.

Fractionalization of NFTs: digital real assets

The DAO or company tokenizes a work of art:

1. The work is purchased by the DAO.
2. ERC-20 tokens representing fractions are issued.
3. Token holders can vote to sell the work.
4. If it sells, they receive the proportion of the price.

Taxation: Distributed profits → capital gains. The holding of tokens → is declared in Form 721 if it exceeds €50,000.

Tokenized invoices: TradFi meets DeFi

Centrifuge and similar allow invoices to be financed through DeFi:

• The company issues an NFT that represents an invoice.
• Investors lend USDC and receive interest when the invoice is collected.
• For the investor: Interest received → movable capital.
• For the financed company: The commissions paid are a deductible business expense.

The challenge of Model 720/721 with RWA

If you have RWA on foreign platforms with a value > €50,000:

• Model 721: Applies if the custody is on-chain (your wallet, foreign platform).
• The type of asset can determine whether model 721 (crypto assets) or 720 (traditional financial investments) applies.
• The border is not clear for RWA → consult with an advisor.

Perspectives: MiCA and RWAs

MiCA (Markets in Cryptoassets Regulation) regulates "asset-referenced tokens" which include many RWAs. The implementation of MiCA can clarify the tax treatment of these assets in Spain.

Updated: April 2026 | Fiscal year: 2025