A Montblanc production mandate on the books in Germany.

What the business has signed.

A production mandate with Montblanc Capital Ltd, a company registered in Dublin, Ireland, under an Allocation Agreement. The business pays a mandate price at signature and in return holds a contractual right to the Bitcoin produced by a defined quantity of hashrate, on infrastructure Montblanc owns and operates, from the signature date to the April 2028 Bitcoin halving. Electricity is invoiced monthly in fiat and passed through at cost. Production is credited to the business daily on a public, signed ledger and settles on-chain each month to a hardware wallet the business controls. At term end a credit of 25% of the mandate price applies against a next-cycle mandate. The business acquires no hardware, no interest in specific machines and no share in Montblanc: it buys a service with a fixed term and a fixed price. Typical counterparties are a GmbH, a UG, a GmbH & Co. KG, or a sole trader or partnership preparing an Einnahmen-Überschuss-Rechnung.

The documents the business receives.

Everything below is issued to the business in its own name and can be handed to you as it stands.

• —The proposal: contracted hashrate, mandate price, term, the projection the economics engine produced on the day, and the electricity rate.
• —The Allocation Agreement, signed digitally by both parties, with the Risk Disclosure Document it references.
• —Monthly electricity invoices in fiat, itemised, with running balances.
• —The public ledger: one signed entry per day for the business's wallet ID, publicly verifiable against Montblanc's published key, and one signed entry per monthly on-chain settlement with the Bitcoin transaction ID.
• —Monthly and annual statements of production, settlements and electricity, in BTC and in fiat at the day's rate.

The mandate price.

A payment at signature for a service delivered over a fixed term.

• —Businesses preparing a balance sheet (Bilanzierung): the payment is an advance for a service received over the term and is generally carried as an aktiver Rechnungsabgrenzungsposten (§250 Abs. 1 HGB; §5 Abs. 5 Satz 1 Nr. 1 EStG), released to expense over the months of the mandate. It is not an asset of the business: no hardware is acquired and no right to specific machines exists.
• —Businesses on a cash basis (Einnahmen-Überschuss-Rechnung, §4 Abs. 3 EStG): the payment is generally deductible when paid (§11 Abs. 2 Satz 1 EStG). §11 Abs. 2 Satz 3 EStG spreads advance payments for a Nutzungsüberlassung of more than five years; the mandate runs well under five years and is a service rather than a Nutzungsüberlassung. Your reading on both points governs.
• —The expense belongs to the business's gewerbliche Einkünfte and therefore also to its Gewerbesteuer base.

Electricity.

Invoiced monthly in fiat and passed through at cost. An ordinary operating expense of the period. The invoices carry the quantity, the rate and the period.

The Bitcoin received.

The BMF letter of 6 March 2025 on the income-tax treatment of crypto assets (replacing the letter of 10 May 2022) treats Bitcoin as a Wirtschaftsgut.

• —Units produced under the mandate enter the business at their market value on the day they are credited; that value is business income (Betriebseinnahme) of the day and becomes the units' acquisition cost.
• —Held units are business assets, valued at acquisition cost and subject to the Niederstwertprinzip where the units are Umlaufvermögen. Classification as Anlage- or Umlaufvermögen follows the intended holding.
• —On disposal the difference between proceeds and acquisition cost is business income or loss. The one-year holding period of §23 EStG applies to private assets only and has no bearing on business assets.
• —The daily ledger gives the quantity per day; the monthly statement gives the fiat value at the day's rate, so the entries can be booked per day or per month as your practice prefers.

VAT.

Montblanc Capital Ltd is established in Ireland and supplies a service to a business customer.

• —The place of supply is Germany (§3a Abs. 2 UStG). The invoice carries no VAT; the business accounts for it under the reverse charge (§13b Abs. 1 UStG) and deducts it as input tax under the ordinary rules (§15 UStG).
• —The Bitcoin itself is outside VAT: exchange of Bitcoin for fiat is exempt (CJEU, Hedqvist, C-264/14), and receiving produced units is not a supply by the business.

The renewal credit.

At term end the business holds a contractual right to a 25% reduction in the price of a next-cycle mandate. Nothing is paid out, and the right lapses if no next mandate is signed. It is generally read as a conditional price concession on a future contract, with no entry until it is used, rather than as income at term end. Your reading governs.

Substance.

§42 AO and the case law on Gestaltungsmissbrauch scrutinise arrangements whose main purpose is a tax advantage. The mandate is a real service with a real cost: hardware procured and run for the term, electricity invoiced monthly, Bitcoin produced every day and settled monthly to a wallet the business controls, a fixed term. The business carries the economic risk of the Bitcoin price and of the network. Montblanc describes the mandate as a business expense that produces a business asset, and nothing else.

Points to settle with your client.

• —Bilanzierung or Einnahmen-Überschuss-Rechnung, and the treatment of the Rechnungsabgrenzung in Handels- and Steuerbilanz.
• —The valuation policy for Bitcoin at the balance-sheet date and its classification.
• —Custody: the business holds the keys to the wallet the Bitcoin settles to. Document the wallet as a business asset from the first settlement.
• —Record-keeping under GoBD: the ledger entries, the invoices and the statements are the primary records.
• —Whether the business is registered for VAT and how the reverse charge is reported in its Umsatzsteuer-Voranmeldung.
• —Montblanc does not provide tax advice, does not file returns and does not structure entities. This brief states what the contract is and how it generally presents; you map it to the rules that apply to your client.