The starting point is that tokens received without consideration raise an income question at the moment they arrive, whether or not you wanted them. What makes unsolicited tokens different is that many have no market you could sell into, so the real issue is less whether to report and more what value to report. Work through the wallet token by token: separate those with an ascertainable value at receipt from those with none, and record the evidence for each. A short schedule with the reasoning written beside it turns an awkward wallet into a defensible position.
Airdrop — meaning in cross-border tax
Airdrop explained: its meaning in cross-border practice, and why it matters to your filing.
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Tokens received without consideration, raising the same timing question as a staking reward: when income arises and at what value.
What it changes
Crypto terms sit on top of rules written for assets with a location. Whether a holding is a foreign account, foreign property, or neither, follows from where the platform is and how the holding is characterised — and the position taken should be documented at the time.

Where the two countries disagree
A definition that is settled at home may be contested in the other country, or may exist there under a different name with different consequences. That is why we identify the governing system before applying the term rather than after.
Where you will actually see it
If you want the practical version rather than the definition, follow one of these.
Putting it to work
If this term has turned up in a letter, a slip or an adviser's email and you are not sure which side of it you are on, that is a short call to the helpline rather than a research project. Bring last year's returns and we will tell you what is missing.
A definition earns its place only when it changes a decision. The ones on this site were chosen because each of them alters a filing, a deadline or a piece of evidence somewhere in a cross-border file, and the term pages say where.
Read and approved for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. Published as general information. For a position on your own file, call the 24-hour helpline.
International tax accountant — what this page covers
Most readers of this page are looking for international tax accountant. What follows sets out how it works for airdrop: who is caught by it, what has to be filed, and what the work costs, agreed before it begins.
Files that look like this one
Sorting a wallet of unsolicited tokens into reportable arrivals
A client's wallet had collected dozens of tokens they had never sought, some tradeable, most not. We went through them one at a time, establishing for each whether a value could be observed on the day it arrived and what evidence supported that. Tokens that could not be transferred at all were recorded with the searches that showed it. The engagement produced a schedule of arrivals with a valuation conclusion and its evidence beside each line, and a short note of the method used, so the same approach carries into later years.
Choosing between the allocation date and the claim date
Tokens had been allocated to the client in one year and claimed by signing a transaction in the next, and the two dates gave very different values. We set out what the client could and could not do with the tokens between those dates, drawing on the project's own documentation, and settled on a single receipt point with the reasoning recorded. The engagement produced a dated position note and a schedule applying that position to every claim the client had made, so the returns for both years rest on the same reading.
Tokens that arrived before a move and were sold after it
A client received an airdrop while resident in one country and sold the tokens after becoming resident in another. Nothing in the file established what the tokens were worth on arrival, which is what decides how much of the movement belongs to each system. We reconstructed the arrival date and value from wallet and market records, and documented the characterisation on both sides. The engagement produced an arrival valuation supported by contemporaneous sources and a disposal computation for the country of sale that starts from it.
Restating a sale that ignored the value taken into income
An earlier return had reported airdropped tokens as income on arrival and then, on sale, reported the full proceeds as gain. The income already taxed had simply not been carried into the cost of the tokens. We tied each disposal to the arrival it came from, adjusted the cost base and restated the computation. The engagement produced a corrected disposal schedule and a single register covering arrivals and sales, so no amount can be counted twice in the years still open.
Answering questions from an authority about token arrivals
A client received a query about credits into a wallet that the authority had treated as unexplained receipts. We assembled a wallet-level record showing which entries were airdrops, which were transfers between the client's own addresses, and which were disposals, and set out the valuation method that had been applied to arrivals. The engagement produced a written reply with a transaction-level annex, and the file now holds the method note that made that reply possible to write in the first place.
Deciding whether an airdropped holding was reportable foreign property
A client held airdropped tokens through a platform established outside their country of residence and wanted to know whether the holding attracted foreign asset reporting as well as an income entry. The answer depended on how the arrangement was characterised and where the platform sat, so we examined the terms governing the client's claim on the tokens. The engagement produced a dated characterisation note and a reporting position applied consistently to both of the client's returns, with the terms relied on kept alongside it.
The Same Income Taxed Twice on Paper
Relief usually exists and is lost to sequence: one country taxes at source and the other credits it, and preparing them in the wrong order claims a credit against a figure nobody has computed.
Read how this one runsDeduction at Source on Deposit Interest, Recovered
Where the treaty rate is lower than what was deducted, the difference comes back through a return rather than at source. The file establishes entitlement and files for the years still open.
Read how this one runsAll case studies — every published engagement in one place.
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A holding structure is only as good as its reporting. Foreign affiliates, accrued passive income and distributions each carry their own return, and the penalties on those attach to the form rather than to any tax being owed — so a structure that saves tax can still cost money if the information returns are late.
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More on Airdrop
That is the timing question this term carries, and there is no single settled answer, so it should be documented rather than assumed. Allocation, appearance in a wallet, and a claim transaction you sign yourself can fall in different months or different years. Look at what you actually controlled at each stage; whether the tokens could be moved or sold before the claim usually drives the argument. Pick a position, write down the facts that support it, and use the same position for every airdrop rather than choosing whichever date suits the year.
If nothing trades, there may be no ascertainable value at receipt, and saying so with evidence is a position rather than a gap. Record what you looked for and when: whether any venue quoted the token, whether transfers were possible at all, and what the token fetched in any observable transaction. Keep the exports you relied on, because this is exactly the kind of fact nobody can reconstruct a year later. If a market appears afterwards, that bears on the later disposal rather than retrospectively on the receipt, and the schedule should show both dates.
Illiquid and worthless are different findings and should be recorded differently. A token you cannot move at all is a poor candidate for a receipt value; a token that trades thinly has a value that is merely hard to establish. Neither is a reason to leave the arrival out of the record. List the token, the date it appeared, what you found about its market and the conclusion you drew. If it is later abandoned or becomes tradeable, the same schedule carries that next event, which is what stops the history being rebuilt from memory.
Each system applies its own rules to the same arrival, so both returns may have something to say about it, and they may not say it in the same year. Two separate questions arise. First, the income question: when each system treats the tokens as received, and at what value. Second, whether the holding itself falls inside either country's foreign asset reporting, which follows from where the platform or wallet arrangement sits and how the holding is characterised. Settle the characterisation once, in writing, and apply it to both returns rather than letting each adviser choose.
Whatever value you brought into income at receipt becomes the cost of those tokens, so a later sale is measured from that point rather than from nothing. Where the conclusion was that there was no ascertainable value on arrival, the cost is correspondingly low and the eventual disposal carries almost the whole movement, which is a consistent answer rather than a contradiction. What cannot work is reporting income on arrival and then computing the sale as though the tokens had cost nothing. Keep the arrival schedule and the disposal schedule together so each sale points back to its receipt.
A branch keeps one taxpayer: results consolidate at home, losses are usable sooner, and the exposure is that the branch is a permanent establishment whose profit the host country taxes, sometimes with a branch tax on repatriation. A subsidiary is a separate taxpayer with limited liability and local rates, at the cost of withholding on dividends home and transfer pricing on everything between them. The deciding facts are usually expected losses, liability and exit plans. See branch against subsidiary.
Only up to your own country's tax on that same income, and only for tax you were legally obliged to pay. Two consequences follow. Living somewhere that taxes you more heavily than your residence country does leaves an excess that becomes a carryover rather than a refund. And withholding suffered above the treaty rate is not creditable — the route back to that money is a refund claim in the country that took it. See claiming the credit.



