Initial Coin Offering (ICO), also referred to as Token
Generating Event (TGE), is a new and, until now, loosely regulated
form of crowdfunding, which is mainly used by companies whose
business model is based on the blockchain technology. In the centre
of this new form of financing is Switzerland; in particular the
so-called Crypto Valley Zug. In addition to regulatory challenges,
aiming to limit the risk of fraud, a TGE also leads to new tax
related questions.
1. Introduction
During a Token Generating Event (hereafter TGE") startups
and established companies issue cryptocurrencies (hereafter
Tokens") which are based on the blockchain technology. The
raised proceeds will be used by the company to fund the announced
project. In contrast to collective debt raising, an initial public
offering, or the increase of the company's equity, raising
funds in the form of a TGE is hardly regulated. In addition, a TGE
can be structured in such way that the investors are not
