marginfiLending
How is lending on marginfi taxed in Germany?
In short
Lending tokens on marginfi isn't selling them. They keep their acquisition date and cost basis, and the one-year holding period keeps running. The interest is income under § 22 Nr. 3 of the Income Tax Act (EStG). TaxMaxi counts it when you withdraw, at its value on that day, because what your balance at marginfi was worth on a past 31 December can no longer be looked up. If your income of this kind stays under €256 in a year, you pay no tax on it.
If you borrow tokens on marginfi against your collateral, that isn't income. The borrowed tokens count as acquired at their market value, and repaying disposes of the tokens you repay with. If your collateral is liquidated, that's a sale under § 23 EStG, at the value of the debt it paid off.
- As of:
- 17 October 2026
- Based on:
- § 23 EStG, § 22 EStG, BMF letter of 6 March 2025
What is marginfi?
marginfi is a lending app on Solana. You lend tokens like SOL or USDC into a marginfi bank, one per token, and other people borrow from it against collateral. The interest they pay is yours. What you've lent can be the collateral for a loan of your own at the same time.
Unlike many other lending apps, marginfi puts no receipt token in your wallet. It keeps your balance as a share of the bank in your marginfi account, an account on the blockchain that only you own. A share's value rises with the interest.
- The app app.marginfi.com You choose what to lend or borrow and confirm in your wallet.
- The program MFv2hW…VacA marginfi v2 takes the tokens into the bank and keeps your share in your marginfi account.
- The banks one per token This is where the lent tokens sit. Other people borrow from them, and the interest they pay makes your share grow.
For tax, all that counts is what happens to your tokens: lent isn't sold, interest is income, a loan is an acquisition and repaying it is a disposal. That's the same on every lending app, with a receipt token or without: How lending is taxed in Germany.
marginfi at a glance
- Type
- Lending on Solana
A marginfi deposit on the blockchain
A real marginfi deposit from a public wallet, the way TaxMaxi reads it. Next to each item the wallet gives up is what it means for tax.
- −0.156472272 SOL Lentnot a disposal, acquisition date and cost stay
- −0.000055 SOL Network feethe SOL paid count as disposed of, and the fee isn't deducted anywhere
Programs called
- marginfiMFv2hW…VacAtakes the tokens into the bank and keeps them in your marginfi account
Nothing comes back into the wallet: the SOL now sits in marginfi's SOL bank, and the wallet's share is in its marginfi account. When you withdraw, the lent SOL comes back, and whatever comes on top of it is the interest.
An example in euros
You buy USDC in May 2024, lend it on marginfi in June, and withdraw it with the interest in March 2025. This is how TaxMaxi works out the interest:
- 1 May 2024Bought 1,000 USDC for €930.00
- 1 June 2024Lent: 1,000 USDC, not a disposal
- 1 March 2025Withdrawn: 1,060 USDC, of which 1,000 USDC back, not a new acquisition
- 1 March 2025Interest on withdrawal: 60 USDC, worth €57.60
- Interest 60 USDC on withdrawal on 1 March 2025
- €57.60
- Income 2025 under the exemption limit of €256
- €57.60
The interest of 2025 stays under the exemption limit of €256 for income like this. If, together with staking rewards and other income under § 22 Nr. 3 EStG, it's your only income of this kind in the year, you pay no tax on it. From €256 the whole amount is taxable, at your personal tax rate.
Part of this interest accrued as early as 2024. Under paragraph 48a it would count at the end of 2024; because the balance back then can't be looked up, TaxMaxi counts all of it at the withdrawal in 2025 and notes that in the report.
Worked out by TaxMaxi's tax engine, on the same principles as for your wallet.
The legal basis
Whether lending costs tax is set in two places in the Income Tax Act (EStG): interest is income from other services under § 22 Nr. 3 EStG, and a sale, a repayment or a liquidation is a private sale under § 23 EStG. How tax offices apply this to crypto is set out in the finance ministry's letter of 6 March 2025, which binds them.
The letter is divided into numbered paragraphs (Randnummern). Each principle below says where to find it; a click opens the letter at that spot.
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1
Lent tokens
If you lend tokens to a lending protocol, you let it use them and don't dispose of them. They keep their acquisition date and cost basis. The receipt token you get for them is only your claim on those same tokens, not a second token, and what comes back of the lent tokens isn't a new acquisition.
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2
Interest from lending
Interest from lending is income under § 22 Nr. 3 EStG at its market value when received, and each interest token gets its own acquisition date. If the interest grows only in the price of your receipt token, it counts at the latest at the end of each year, at the price of 31 December, and the rest when you withdraw the tokens.
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3
The exemption limit (Freigrenze) for income
Income from other services under § 22 Nr. 3 EStG is tax-free if it stays under €256 in the year.
See the BMF letter, paragraph 45
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4
One-year holding period
The year runs from the day of acquisition to the swap, and each swap starts it again for the token you receive. There's no extension to ten years. For tokens you acquire from 2027, a finance ministry draft would drop the holding period: What is set to change from 2027.
- 5
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6
Repaying a loan
When you repay a loan, you dispose of the repaid tokens at their market value. With a stablecoin loan that gives hardly any gain or loss; with a volatile token there can be one. What you repay beyond the amount you borrowed is the interest: it's disposed of the same way and is a private cost that isn't deducted anywhere.
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7
Liquidation
If a liquidator takes your collateral because your loan has grown too large, you dispose of it. The proceeds are the value of the debt the liquidator paid off with it, and the liquidator's premium is your loss. If the acquisition was less than a year ago, the gain or loss counts.
Common questions
Why does interest on marginfi only count when you withdraw?
Because the balance at a past year end can't be looked up. Under the finance ministry's letter of 6 March 2025, lending income counts when you receive it (paragraph 65), at the latest at year end (paragraph 48a). marginfi has no receipt token: your share's value is only in the bank's account, and the blockchain shows it for today, not a past day.
So TaxMaxi counts interest at withdrawal, and for each one across a year end the report notes that part would belong to the year before under paragraph 48a. In strangers' wallets we read, that was mostly cents.
Is lending itself taxable?
No. When you lend, you hand over tokens for use in return for payment (paragraph 26), and you don't sell them. The lent tokens keep their acquisition date and the one-year holding period keeps running. If you sell them after withdrawing, more than a year after you bought them, the gain is tax-free, even if they were lent out most of that time.
What happens for tax when I take out a loan on marginfi?
The borrowed tokens are yours to use: you can spend or swap them. When you borrow, they count as acquired at their market value, and they aren't income. When you repay, you dispose of the tokens you repay with. On a USDC loan that gives hardly any gain or loss; on a volatile token it can. Whatever you repay above the loan is interest: a private cost that isn't deducted anywhere. The BMF letter says nothing explicit about loans; TaxMaxi follows what it says about acquisitions and swaps.
What happens in a liquidation?
If your loan gets too large for your collateral, a liquidator takes part of the collateral and pays off part of your debt in return. For tax, you're selling the tokens taken, and the proceeds are the value of the debt paid off; the liquidator's premium is your loss. If you bought the tokens less than a year ago, the gain or loss counts. A liquidation doesn't show up in your wallet, only in the history of your marginfi account, and TaxMaxi reads it there.
When does TaxMaxi ask me about marginfi?
With a flash loan or loop that lends, borrows and swaps in one transaction: after it, TaxMaxi no longer knows for sure how much of your balance is lent and how much is interest, so it asks at your next withdrawal. It also asks when you withdraw something whose deposit it hasn't seen, because the deposit happened before your wallet began or came from another wallet. The date and amount of what you lent are then missing, and only you know them, so TaxMaxi puts the transaction in front of you in the review.
More Solana protocols
This page explains how TaxMaxi calculates. It is not tax advice and does not replace a tax advisor.