Germany’s Federal Ministry of Finance has proposed a 50% substitute assessment basis for crypto sales when taxpayers cannot provide credible purchase-cost records. The rule would assume purchases occurred after December 31, 2026, and calculate the tax basis at half of the sale proceeds. Patrick Hansen, Senior Director, EU Strategy & Policy at Circle, said the approach could particularly burden less experienced retail investors who bought at small profits or losses. Dr. David Hötzel, Associated Partner at Poellath, said the measure is not final but acknowledged significant liquidity risks, especially for transfers from self-custody wallets or foreign platforms to German exchanges. Both views emphasize the importance of reliable documentation.