In Quebec, simply holding crypto assets requires taxpayers to attach Form TP-21.4.39 — Cryptoasset Return to the tax return they are required to file, even if they made no purchases or sales during the year. This requirement has applied since the 2024 taxation year. Special rules apply to partnerships.
Form TP-21.4.39 is used to report the holding of crypto assets and to disclose the resulting gains, losses and income. The form does not, by itself, impose additional tax. This guide explains who must file it and how to complete it, based on the 2025-12 version of the form.
Who Must File Form TP-21.4.39?
Section 21.4.38 of Quebec's Taxation Act defines the term "crypto asset," while section 21.4.39 requires taxpayers who hold, receive, dispose of, or use crypto assets in a transaction during the taxation year to attach the prescribed form to their Quebec income tax return, if they are required to file one. A similar requirement applies to partnerships required to file an information return.
The form must accompany the Quebec income tax return or information return that the filer is required to submit.
| Filer | Quebec return | Line on which to answer “Yes” |
|---|---|---|
| Individual, including a self-employed individual | TP-1 | Line 24 |
| Corporation | CO-17 | Line 19b |
| Trust | TP-646 | Line 31 |
| Partnership | TP-600 | Line 25a |
These references appear in the instructions for Form TP-21.4.39. For partnerships required to file a TP-600 return, Guide TP-600.G-V specifies that the requirement applies to fiscal periods ending in 2025 or later.
Must Crypto Assets Be Reported Even Without a Taxable Transaction?
Yes. There is no minimum value or minimum number of transactions required to trigger the reporting obligation. An individual who holds Bitcoin during the year and keeps it without selling it must attach the form to their Quebec tax return. The same rule applies to a corporation holding crypto assets as investments or in its treasury.
What Transactions Are Covered?
The form covers, among other things, the following situations:
- Holding or acquiring crypto assets, even without reselling them.
- Selling or exchanging crypto assets, including for Canadian dollars or other crypto assets.
- Using crypto assets to pay for goods or services or to make a donation.
- Receiving crypto assets, including as payment of an invoice.
- Receiving rewards from mining or staking activities.
Revenu Québec includes cryptocurrencies, stablecoins, non-fungible tokens (NFTs), utility tokens, security tokens and privacy coins among the types of crypto assets covered.
How to Complete Form TP-21.4.39
The form has five parts. Parts 1, 2 and 3 identify the filer, the reporting period and the holding of crypto assets. Part 4 reports gains, losses and income according to their tax characterization. Part 5 is for the signature.
Parts 1, 2, 3 and 5: Identification, Holdings and Signature
Part 3 asks whether the filer held crypto assets at the end of the reporting period. The filer must answer “Yes” or “No”.
Under the instructions for the 2025-12 version, a filer who merely held or received crypto assets without disposing of or using them completes only Parts 1, 2, 3 and 5, except in particular where the crypto assets were received from mining or staking activities.
Conversely, someone who sold all their crypto assets during the year may answer “No” to the question about holdings at the end of the period while still being required to complete Part 4.
Part 4.1: Capital Gains and Losses
This part covers dispositions of crypto assets held as capital property. For each category of crypto assets shown on the form, the filer reports:
- total proceeds of disposition;
- total adjusted cost base (ACB) of the assets disposed of;
- expenses incurred to make the dispositions;
- the resulting capital gain or loss.
The total capital gains and losses are entered on line 49. This is the capital result before applying the rules governing the taxable portion of capital gains.
Example — Exchanging BTC for ETH
An individual exchanges 0.2 BTC for ETH with a fair market value of CAD 11,000. The ACB of the BTC disposed of is CAD 8,000. Assume the BTC are held as capital property.
| Capital gain calculation | Amount |
|---|---|
| Proceeds of disposition of the BTC | CAD 11,000 |
| ACB of the BTC disposed of | (CAD 8,000) |
| Capital gain | CAD 3,000 |
The CAD 3,000 gain is included in the calculation in Part 4.1 and, for this individual, must be taken into account on Schedule G of their Quebec income tax return. The exchange constitutes a disposition even though no amount was converted into Canadian dollars. In this example, the ETH received has an initial acquisition cost of CAD 11,000, before any other applicable adjustments.
Part 4.2: Business Income and Losses
This part applies to crypto asset transactions that give rise to business income or losses, including where crypto assets are held as inventory in a trading business.
Two totals must be calculated:
- Line 111: gross business income from crypto assets.
- Line 112: net business income or loss from crypto assets.
A distinction is necessary for businesses that accept crypto assets as payment. Income from the goods sold or services provided remains reportable under the usual tax rules. According to the instructions for Form TP-21.4.39, a taxpayer who receives crypto assets, even in the course of carrying on a business, and neither disposes of nor uses them during the relevant period is generally required to complete only Parts 1, 2, 3 and 5. The treatment is different for rewards from mining and staking.
For a self-employed individual or a trust, Form TP-80 — Business or Professional Income and Expenses, or the applicable financial statements, must also be provided in accordance with the form's instructions.
Part 4.3: Income and Losses From Property
Part 4.3 is used to report income or losses from property arising from crypto assets. The total is entered on line 135.
Certain payments connected with holding crypto assets or making them available to others may constitute income from property. However, staking rewards do not automatically fall into this category: their characterization depends on the activities carried on and the circumstances.
Where Are the Totals Reported on Other Returns?
Form TP-21.4.39 provides the following cross-references:
| Filer | Capital gains and losses — line 49 | Business income — lines 111 and 112 | Income from property — line 135 |
|---|---|---|---|
| Individual | Schedule G of TP-1, line 21 | For a self-employed individual: Schedule L, lines 16.1 and 26.1 | TP-1, line 130 |
| Corporation | Schedule CO-17S.232 and Form CO-17.A.1, line 40 | Included in corporate results, with no separate line on CO-17 | Included in corporate results, with no separate line on CO-17 |
| Trust | Schedule A of TP-646, line 217, or TP-653, line 19, as applicable | TP-646, lines 55a and 55 | TP-646, line 61, with code 07 on line 61a |
| Partnership | TP-600, line 62 | TP-600, lines 34.1 and 44.1 | TP-600, line 52 |
These cross-references do not replace the application of tax rules concerning, among other things, ACB calculations, superficial losses, and the distinction between capital property and inventory.
Must Each Crypto Asset and Transaction Be Reported Separately?
No. Part 4 reports amounts aggregated by category of crypto assets, rather than listing every transaction. The instructions distinguish cryptocurrencies, stablecoins, NFTs, utility tokens, security tokens and privacy coins.
Accordingly, results from BTC and ETH are combined under the cryptocurrency category. However, their ACBs must not be pooled together for the underlying tax calculations: the result must first be calculated correctly for each property, and the amounts are then presented according to the categories on the form.
If there is insufficient space in Part 4, an additional copy of Form TP-21.4.39 must be used, and the totals from lines 49, 111, 112 and 135 must be consolidated on a single copy.
What Records Must Be Kept?
The aggregated amounts on the form must be supported by detailed records. The official instructions call for records that include, among other things:
- the type and quantity of crypto assets involved in each transaction;
- the date and time of transactions;
- the value in Canadian dollars at the time of each transaction;
- the nature of the transaction and available information about the counterparties;
- the addresses of the wallets used;
- opening balances and costs, and closing balances, by crypto asset.
Supporting documents must also substantiate fees, ACBs, income and transfers between wallets.
As a general rule, records and supporting documents are kept for six years after the last year to which they relate. Documents needed to establish the cost of crypto assets that are still held may have to be retained longer.
When and How Must Form TP-21.4.39 Be Filed?
The form must be attached to the relevant income tax return or information return and submitted no later than the filing deadline for that return.
| Filer | Usual filing deadline |
|---|---|
| Individual | April 30 of the following year |
| Individual who, or whose spouse, carries on a business | June 15 of the following year, subject to the applicable conditions |
| Corporation | Six months after the end of the taxation year |
| Trust | 90 days after the end of the taxation year |
| Partnership | Depends on the members and the rules applicable to Form TP-600 |
For individuals, any balance of income tax owing must be paid by April 30, even if they have until June 15 to file their tax return. If April 30 falls on a weekend, the payment deadline is extended to the next business day. Revenu Québec describes the relevant rules and exceptions for individuals, corporations (French only), trusts and partnerships.
Form TP-21.4.39 is available on Revenu Québec's website and may be prepared using compatible tax software. The method of submission depends on the type of return, the software used and any restrictions applicable to the year concerned.
What Penalties May Apply?
According to the instructions for Form TP-21.4.39:
- Failure to file the form: a penalty of CAD 25 per day, up to CAD 2,500, may apply.
- Missing or incorrect information: a penalty of CAD 100 per item may apply.
The application of these penalties depends on the conditions prescribed by the relevant tax legislation. In particular, sections 59 and 59.0.2 of Quebec's Tax Administration Act provide penalties for certain failures to file and omissions of information.
How Can a Previously Filed Form Be Corrected?
If a filer discovers that they omitted income from crypto assets on a Form TP-21.4.39 already submitted for 2024 or a subsequent year, the instructions require a new copy of the form with box 01 checked to indicate that it is an amended form.
The related income tax return or information return must also be amended if the reported amounts are affected. Form TP-21.4.39 did not apply to 2023 or earlier years: corrections for those years must instead be made to the relevant tax returns.
Does Form TP-21.4.39 Replace Other Tax Reporting Requirements?
No. This form is a separate Quebec reporting requirement. It does not replace the income tax return or any forms required to calculate the taxable result.
It is also distinct from foreign property reporting, including federal Form T1135 — Foreign Income Verification Statement and Quebec Form TP-1079.8.BE — Foreign Property Reporting. These returns have different applicability criteria. Merely holding crypto assets, even on a foreign platform, does not automatically establish that they are specified foreign property or designated foreign property.
Need Help Reporting Your Crypto Assets?
Preparing Form TP-21.4.39 may require reconstructing years of transactions and distinguishing transfers, dispositions and income across multiple wallets or protocols.
Token Expert assists individuals and corporations with reconstructing their transactions, calculating gains and losses, and preparing the information needed for their tax filings.
Contact our team to discuss your situation.
References Consulted
- National Assembly of Quebec. Taxation Act, CQLR, chapter I-3, sections 21.4.38 and 21.4.39.
- Revenu Québec. Form TP-21.4.39 — Cryptoasset Return, version 2025-12 (PDF).
- Revenu Québec. Crypto Assets.
- Revenu Québec. Guide TP-600.G-V — Guide to Filing the Partnership Information Return.
- Canada Revenue Agency. Reporting Income From Crypto-Asset Transactions.
- Revenu Québec. Deadline for Filing Your Income Tax Return.
- Revenu Québec. Corporation Income Tax (available in French only).
- Revenu Québec. Trusts.
- National Assembly of Quebec. Tax Administration Act, CQLR, chapter A-6.002, sections 59 and 59.0.2.
- Canada Revenue Agency. Form T1135 — Foreign Income Verification Statement.
- Revenu Québec. Form TP-1079.8.BE — Foreign Property Reporting.
Disclaimer
This article is provided for informational purposes only and does not constitute tax, accounting or legal advice. The applicable treatment depends on the facts and the taxpayer's circumstances. Tax rules and filing requirements must be verified for the relevant taxation year.
Last reviewed: October 23, 2026.
