Cryptocurrency activities increasingly involve multiple jurisdictions, whether through cross border investments, international business operations, decentralised platforms or global investor bases. These situations raise specific challenges in terms of qualification, valuation, taxation and reporting.

Differences between domestic tax rules, limited international coordination and rapidly evolving regulatory frameworks can expose individuals and companies to uncertainty and double taxation risks. A structured and internationally coordinated approach is therefore essential when cryptocurrency activities extend beyond one jurisdiction.

RSM Switzerland supports clients in managing the international aspects of cryptocurrency taxation, combining local Swiss expertise with the capabilities of the RSM global network.

International tax challenges related to cryptocurrencies

Differences in tax qualification across jurisdictions

Cryptocurrencies and tokens may be classified differently depending on the country involved. While some jurisdictions treat crypto assets as private property, others may consider them financial instruments, commodities or currencies for tax purposes.

These differences can affect:

  • the timing and nature of taxable events
  • the distinction between capital gains and income
  • applicable reporting obligations

Understanding how each jurisdiction qualifies and taxes crypto activities is key to avoiding inconsistent treatment.

Cross border transactions and double taxation risks

International crypto activities may give rise to double taxation, particularly when:

  • gains are taxed differently in more than one country
  • income is recognised at different moments in different jurisdictions
  • tax residence is unclear or disputed

Double taxation treaties may only partially address these issues, as many treaties were not designed with digital assets in mind. Careful structuring and documentation are therefore required.

Switzerland in an international crypto context

Switzerland as a crypto friendly environment

Switzerland is widely recognised for its pragmatic approach to cryptocurrencies and blockchain technology. Over time, several cantons and cities have developed initiatives aimed at supporting innovation, while maintaining a clear tax and regulatory framework.

Examples include:

  • the canton of Zug, which has long been associated with the development of Crypto Valley
  • selected municipalities accepting tax payments in cryptocurrencies
  • local initiatives fostering blockchain and digital asset ecosystems

While these elements contribute to Switzerland’s attractiveness, tax and regulatory treatment continues to rely on existing legislation and administrative practice rather than on special incentive regimes.

Cantonal practices and cross border considerations

Cantonal tax authorities may apply different practices, particularly when assessing activities such as mining or professional trading. Cross border situations therefore require careful coordination between federal guidance, cantonal practice and foreign tax rules.

Our international support

How RSM Switzerland supports international crypto situations

RSM Switzerland assists individuals and companies involved in international cryptocurrency activities, including:

  • analysis of cross border crypto tax positions
  • coordination of tax treatment across multiple jurisdictions
  • mitigation of double taxation risks
  • interaction with Swiss and foreign tax authorities
  • structuring of international crypto investments and operations
  • collaboration with RSM member firms worldwide

Our approach combines technical expertise with a practical understanding of how tax authorities apply existing rules to digital assets.

Meet our Tax & Legal & Crypto experts

Managing Partner, Head of Tax Switzerland
Partner Tax & Legal
Division
Senior Manager Tax & Legal