A Montblanc production mandate on the books in Switzerland.

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 an AG, a GmbH, or an Einzelunternehmen keeping accounts under the Code of Obligations.

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 keeping accounts under Art. 957 ff. OR apply periodengerechte Abgrenzung (Art. 958b OR): the payment is carried as aktive Rechnungsabgrenzung and released to expense over the months of the mandate. It is a service, not an asset: no hardware is acquired.
• —The expense is geschäftsmässig begründeter Aufwand (Art. 58 and 59 DBG and the cantonal equivalents) and reduces taxable profit for direct federal, cantonal and communal tax.
• —Sole proprietors below the thresholds of Art. 957 Abs. 2 OR keeping simplified accounts generally record the payment when made.

Electricity.

Invoiced monthly in fiat and passed through at cost. An ordinary expense of the period, with quantity, rate and period on each invoice.

The Bitcoin received.

The Federal Tax Administration's working paper on cryptocurrencies and ICOs (updated December 2021) sets out the treatment for profit, income and wealth tax.

• —Units produced under the mandate are Ertrag of the business at their market value on the day they are credited, and enter the accounts at that value.
• —Held units are assets under Art. 960 ff. OR. Assets with an observable market price may be carried at that price (Art. 960b OR); the Federal Tax Administration publishes year-end rates for Bitcoin. Gains and losses on business assets are part of taxable profit; the private capital-gains exemption does not apply to business assets.
• —Direct federal tax applies at 8.5% on profit after tax, plus the cantonal and communal rates of the business's seat.
• —The daily ledger gives the quantity per day; the monthly statement gives the fiat value at the day's rate.

VAT.

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

• —The service is received from abroad and is subject to Bezugsteuer (Art. 45 MWSTG) at the standard rate. A VAT-registered business declares it in its return and deducts it as Vorsteuer under the ordinary rules; a business that is not registered owes it once such services exceed CHF 10,000 in a calendar year.
• —The Bitcoin itself is outside VAT: the Federal Tax Administration treats Bitcoin used as a means of payment like legal tender, 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.

The Steuerumgehung doctrine of the Federal Supreme Court 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.

• —The canton of the seat and its rates.
• —The valuation policy for Bitcoin at the balance-sheet date under Art. 960 ff. OR.
• —Custody: the business holds the keys to the wallet the Bitcoin settles to. Document the wallet as an asset of the business from the first settlement.
• —VAT registration and the declaration of the Bezugsteuer.
• —The fiat value series for the Ertrag: the monthly statement is prepared at the day's rate and can be re-based to the rate source your practice uses.
• —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.