Tax and Accounting Treatment of Utility and Security tokens in Switzerland

Initial Coin Offerings (ICOs) or tokens sales are widely used by blockchain start-ups as an instrument to accelerate the token distribution to the public and fund the project. Switzerland became one of the world’s leading token sale hubs due to its crypto friendly nature and advantageous legal conditions. Yet little is known about the token sale taxation and its accounting treatment.

Hanna Keskin
Jan 15 · 8 min read

Security tokens

In the case of a security token, a contractual relationship is established between the purchaser of the token and the issuer with no reimbursement obligation for the issuer. The payments that the issuer will make to the token investors will depend on the performance of the startup’s annual earnings before interest and taxes (EBIT) or profit on the balance sheet or license income (depending on what was promised to investors as a counter value).

Utility token

Normally the issuer of the utility token has an obligation towards investors to use the funds collected for the purpose of developing the platform/software in blockchain, growing the network around the project or more. It is therefore not a silent participation but rather a mandate contract according to which the issuer undertakes to develop the platform in blockchain and provide token utilities to investors. An example of such utilities can be the utilities provided by the GRG token. The GRG token gives users access to the platform built on top of the RigoBlock protocol, helps to establish a meritocratic and incentives-based framework for traders, modify the fee logic and creates an incentives mechanism without additional payment or asset functionalities.


The tax and accounting measures described above might be useful for those thinking about their own token sale. Hence the approach might be different, depending on each case. That is why every token sale needs to be examined individually.


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