What the Brazil crypto asset reporting regime covered
The instruction created an information-reporting obligation to the Secretaria Especial da Receita Federal do Brasil for operations involving “criptoativos.” It defined a crypto asset as a digital representation of value, denominated in its own unit of account, transferable electronically with cryptography and distributed-ledger technology, and not legal tender. It also defined a crypto-asset exchange broadly to include non-financial legal entities offering intermediation, trading, or custody services, including environments where users could buy and sell crypto assets with one another.
Reporting applied to exchanges domiciled in Brazil for tax purposes. It also applied to Brazilian-resident or Brazil-domiciled individuals and legal entities when operations were carried out through a foreign exchange or outside an exchange, but only when the monthly value of those operations, alone or together, exceeded R$30,000. This structure made the regime both platform-facing and taxpayer-facing, while preserving a threshold for the foreign-exchange and off-exchange reporting category.