Taxation Of Blockchain And Crypto Currency – A Case Study

I. Introduction

So called Initial Coin Offerings ("ICO") as a new fundraising mechanisms in which new projects sell their underlying crypto tokens in exchange for e.g. Bitcoin or Ether, have often been discussed in recent months. In order to contribute our part in this dialog we would like to discuss a fictional case of a company intending to finance the development and fabrication of its product through an ICO. In this connection we observe the different stages of a planned ICO from a Swiss tax perspective and provide an overview of the different tax issues relating to this topic.

II. Fictional Case

Nurse Robo Ltd. based in Zug, Switzerland plans to develop, produce and sell a robot for the nursing industry which will facilitate the daily care of the elderly. Apart from the development and the production of the nursing robot the corporation plans to create a platform on which customers will have access to the "Nurse Robo Education Program" and further