Bitcoin, tokens, ICO, blockchain, mining - Terms related
to crypto currencies are on everyone's lips. However, there are
many open questions and uncertainties, especially regarding the VAT
treatment of individual transactions with digital currencies. The
fact that the Swiss Federal Tax Administration (SFTA) has not yet
made an official statement on the subject does not make things any
easier.
The services provided by taxable persons in return for payment
(deliveries or services) are subject to VAT, unless they are exempt
from tax (Art. 18 para. 1 VAT law). A typical VAT-liable service
involves the sale of goods in Switzerland. If, on the other hand,
funds are paid without counter-performance of a service, there is
no performance relationship in the sense of value-added tax. These
types of funds flows do not qualify as consideration and are
therefore not subject to VAT.