Bitcoin Savings Plan and Tax: How the Holding Period, FIFO and the Exemption Limit Interact on Monthly Buys

A Bitcoin savings plan takes the timing question off your hands. You buy a fixed amount every month, whether the price is rising or falling. Tax law grants you no such convenience: twelve instalments a year become twelve separate acquisitions, each with its own date, its own price and its own clock.
For you as an investor, that has one consequence. Whether a later sale stays tax-free is decided at the level of the individual tranche and the order in which the tax authorities treat those tranches as sold, never at the level of your total holding. Sell after three years of a savings plan and you do not hold one uniform stock of Bitcoin; you hold 36 acquisitions with 36 deadlines. This article sorts out the mechanics: holding period, exemption limit, order of disposal, valuation and record-keeping, each with its source.
Why a Bitcoin savings plan consists of many separate purchases for tax purposes
A savings plan is technically a standing order to buy: the exchange executes an order on a fixed date and credits you with the fraction of a Bitcoin you have acquired. For tax purposes, each of those executions is an acquisition within the meaning of German income tax law, with its own point in time, its own acquisition cost and its own holding period.
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