Prior to an ICO of one of our clients we have obtained a leading tax ruling related to the taxation of the proceeds from the ICO. In a nutshell, the respective proceeds will not be subject to corporate income tax in Switzerland. Instead, the client will be taxed on a cost plus 5% basis in the next few years, i.e. during the development phase.
This procedure will most likely turn out to be the model taxation for most of the ICOs we will see in Switzerland in the next few months.
The VISCHER team was led by Christoph Niederer and Dr. Jana Essebier (both Partner).