Cryptocurrencies for companies

Cryptocurrencies and digital assets are increasingly used by companies as investment assets, means of payment, financing tools or as part of blockchain based business models. These activities raise complex questions from a tax, accounting, regulatory and reporting perspective.

In Switzerland, there is no specific cryptocurrency legislation. The treatment of cryptocurrencies therefore relies on existing accounting, tax and regulatory rules, as well as the established practice of tax authorities and FINMA. For companies, the correct classification and accounting treatment of crypto assets is essential, as it directly impacts taxable income, cash flow, reporting obligations and regulatory exposure.

RSM Switzerland supports companies at all stages of their cryptocurrency activities, from holding and trading digital assets to issuing tokens through ICOs or ITOs.

Cryptocurrencies held or traded by companies

Legal qualification of cryptocurrencies

Under Swiss law, cryptocurrencies such as Bitcoin:

• are not legal tender, as only the Swiss National Bank may issue legal tender
• are not foreign currencies
• are not considered goods or services
• are qualified as objects within the meaning of Swiss civil law

This qualification explains why cryptocurrencies are generally treated as assets rather than monetary instruments for accounting and tax purposes.

Accounting classification and valuation

Cryptocurrencies held by a company must be recognised in the balance sheet. The appropriate classification depends on the role cryptocurrencies play in the company’s activities.

Common accounting treatments include:

• classification as securities, like gold or precious metals
• classification as inventory, where crypto trading represents a substantial part of the ordinary operating activity

Cryptocurrencies may be held either for the short term or as a long term investment, which influences their balance sheet presentation.

For valuation purposes, companies generally have the option to apply:

• the acquisition cost or lower value principle
• an observable current market price, based on reliable trading platform data or reference values published by the Swiss Federal Tax Administration

Transaction costs are typically recognised as expenses, although they may also be capitalised as part of acquisition costs, depending on the accounting policy applied.

The chosen valuation method must be applied consistently and has direct implications for the financial statements and taxable income.

Reporting, volatility and accounting processes

Due to the volatility of cryptocurrencies, companies often need to adapt their reporting systems and processes.

This may include:

• tracking capital gains and losses
• adapting internal reporting to reflect valuation changes
• automating crypto accounting using specialised software or dedicated modules

Where crypto holdings are significant, separate presentation in the financial statements may be required to ensure transparency. Valuation methods and any fluctuation reserves must be disclosed in the notes to the accounts where applicable.

Corporate income tax

For corporate taxpayers, all gains realised on cryptocurrencies held as business assets are subject to Swiss corporate income tax. This includes capital gains.

Unlike private wealth, losses and value adjustments recognised on cryptocurrencies held by a company are generally tax deductible. As a result, the accounting treatment selected plays a decisive role in determining the timing and amount of taxable income, as well as the associated cash flow impact.

This link between accounting and taxation, known as the principle of determinacy, makes early planning particularly important.

Capital tax

Cryptocurrencies recorded as assets in the balance sheet are generally not subject to Swiss capital tax. Cantonal specificities and the company’s overall capital structure should nevertheless be reviewed.

Stamp duties

Certain transactions involving cryptocurrencies may trigger Swiss transfer stamp duty. This is notably the case for:

• foreign capital tokens
• asset backed tokens granting voting rights

Stamp duty exposure must be assessed on a case by case basis, depending on the legal characteristics of the token and the transaction structure.

Value added tax (VAT)

For VAT purposes, cryptocurrencies are treated in a similar manner to traditional currencies. Transactions involving cryptocurrencies are therefore generally exempt from VAT.

However, specific business models and associated services may require a detailed VAT analysis, particularly where crypto activities are integrated into broader commercial operations.

Tokens issued by companies through ICO or ITO

Regulatory and FINMA considerations

Companies may issue their own tokens as part of fundraising or project development through ICOs or ITOs. FINMA guidelines indicate that financial market regulations do not automatically apply to all token issuances. Instead, the regulatory treatment depends on the nature, purpose and transferability of the token.

In practice:

• asset backed tokens are generally considered securities
• utility tokens may be considered securities unless they exclusively grant access to an already operational service
• native tokens are not considered securities, although anti money laundering rules remain applicable

Income tax treatment of funds raised

The tax treatment of funds raised through an ICO or ITO depends on the type of token issued.

Funds raised through the issuance of asset backed tokens with voting rights are generally treated as capital and are not subject to income tax. Interest paid on foreign capital tokens is typically deductible as a business expense.

By contrast, funds raised through contractual asset backed tokens and utility tokens are generally treated as taxable income. Contractual payments made to token holders may be deductible, subject to the specific structure.

Capital tax, withholding tax and stamp duties

The issuance of asset backed tokens with voting rights may trigger Swiss capital tax at company level. Some cantons allow income tax credits to offset capital tax.

Issuers of foreign capital tokens may be required to withhold tax on interest payments when applicable thresholds are met. Asset backed tokens with voting rights may also trigger withholding tax obligations like dividend distributions.

Issuance stamp duty may apply where token rights are comparable to share rights. In such cases, transfer stamp duty is generally not due for investors.

VAT implications of token issuance

The issuance of tokens is generally not subject to VAT, regardless of the type of token issued. Nevertheless, associated services and contractual arrangements should be reviewed to confirm VAT treatment.

Our support for companies

How RSM Switzerland supports corporate clients

RSM Switzerland advises companies on all tax, accounting and regulatory aspects of cryptocurrencies, including:

• accounting classification and valuation of crypto assets
• corporate income tax, capital tax and VAT implications
• regulatory and FINMA related matters
• ICO and ITO structuring and taxation
• withholding tax and stamp duty analysis
• reporting, automation and internal process adaptation
• group restructuring and cross border coordination through the RSM network

Our multidisciplinary teams provide practical, coordinated solutions tailored to each company’s business model and growth strategy.