The emergence and spread of crypto-currencies have raised various questions about the tax treatment of these book-entry securities. The Swiss Federal Tax Administration (FTA) has published a working paper outlining the practice developed to date (status end of May 2019).
The working paper deals with cryptocurrencies and Initial Coin/Token Offerings (ICOs/ITOs) as subject to property, income and profit tax, withholding tax and stamp duties.
The categorisation of coins/tokens used in the working paper is based on the FINMA guidelines on questions of subordination regarding Initial Coin Offerings (ICO) dated 16 February 2018.
The working paper sets out the tax treatment of cryptocurrencies in the form of pure digital payment instruments (native tokens/payment tokens) held by investors in private assets. Furthermore, the tax consequences of the Coins/Tokens issued in the context of ICOs/ITOs with monetary rights vis-à-vis a counterparty (asset-backed tokens) and with the issue of utility tokens are presented. Both the level of the investor (private assets or, if applicable, employment) and that of the issuer are covered. Finally, the working paper also addresses the issue of the cantonal wealth tax.
The working paper is available as PDF here.
