The mandate is a service, not a hardware purchase.

The structural premise.

You don't own the hardware. Montblanc does, and operates it on your behalf in a contracted facility. What you own is a contractual right to the BTC output of a specified amount of hashrate over the mandate term. That is a service, in the same accounting sense that a multi-year software licence, a maintenance contract, or a prepaid industrial lease is a service. Once that premise is in place, the tax treatment follows.

Timing of the deduction — two paths.

Which path applies depends on the legal entity that signs the mandate and its accounting basis. Both are materially better than the 3–5 year depreciation schedule that owning hardware would produce.

• —Accrual-basis operating companies (GmbH, SARL, S.A.S., S.R.L., Ltd, S.A. and equivalents — most operating businesses above small-business thresholds): the prepayment is recognised as expense over the period the service is delivered. For a mandate signed today running ~24–30 months to April 2028, the capex is amortised across that period. Cleaner P&L than hardware ownership — no fixed asset on the balance sheet, no depreciation schedule to maintain, no end-of-life disposal entry.
• —Cash-basis self-employed taxpayers and certain small-business structures (Einnahmen-Überschuss-Rechnung in Germany, régime micro / réel simplifié in France, comparable structures elsewhere): §11 EStG (Germany) and equivalents permit deduction at time of payment for service prepayments under five years. A 24–30 month mandate sits well inside that window — the full capex is typically deductible in the year of payment for these clients.

Electricity — ongoing operating expense.

Electricity is invoiced monthly in EUR or USD at cost — no markup, no margin layered on. Treatment is ordinary business operating expense, deductible against business income in the period incurred. We supply itemised monthly invoices for your accountant's records.

BTC received — business income at fair value on day of receipt.

Each monthly distribution is treated as business income equal to the fair market value of the BTC on the day of settlement. That day's value becomes the cost basis for the BTC you now hold. Subsequent appreciation is not a taxable event until disposal — the BTC accumulates on the corporate balance sheet at original cost basis, and is taxed as a capital gain (or under jurisdiction-specific crypto rules) when you eventually dispose of it. Until then, paper appreciation is not recognised.

Why this structure is materially better than the alternatives.

A personal-account BTC purchase gives you no business deduction at all — you've used post-tax cash and accumulated BTC at market price. Owning mining hardware directly forces a 3–5 year depreciation schedule plus end-of-life disposal, and ties up your books with an industrial asset register you didn't ask for. A Montblanc mandate occupies a third structural position: pre-tax business expense recognised against business income over the service period, with BTC accumulating at production cost rather than market cost. The combination is hard to replicate through other vehicles.

Anti-abuse rules and economic substance.

European jurisdictions carry anti-abuse provisions — §42 AO in Germany, abus de droit in France, comparable rules elsewhere — that scrutinise transactions whose primary purpose appears to be tax avoidance. The mandate has substantial economic substance: Montblanc procures and installs real hardware, the service is real, the BTC distributions are real, the term is fixed. The capex pre-payment is structural to how the service is delivered, not a tax-engineering device. That substance is the defence. We never describe the mandate as a shelter, loophole, or deferral mechanism — it is a real business expense that is structurally more efficient than the alternatives, and that's the only honest framing.

Documentation we provide.

The artefacts your accountant needs to map the mandate to local tax code.

• —The mandate contract — service-provision basis, capex, term, contracted hashrate.
• —Monthly itemised invoices — electricity passthrough, with running balances.
• —Monthly distribution proofs — signed daily ledger entries plus the on-chain TXID for the corresponding monthly settlement.
• —Proposal page — the economics anchor we both sign.

What we don't do.

We don't provide tax advice. We don't file your business's returns. We don't structure your corporate entities. We don't tell your accountant how to apply local code. We supply the artefacts; your accountant maps them to the rules that apply in your jurisdiction. Some accountants encounter this mandate structure for the first time when their client signs one — we're available to walk through the service-provision shape with them directly, in writing or on a call. That is a service to your accountant, not advice to you.