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Thierry Obrist and Roland A. Pfister

The number of Bitcoins in circulation has grown from over 5 million in 2011 to approximately 16.95 million in March 2018. Unfortunately, this accelerated growth pace has not been followed by the correspondent regulation of cryptocurrency from a tax perspective. While the tax consequences of certain aspects may be anticipated (e.g., payments to an employee made in cryptocurrencies will likely be assimilated to salary), the answer to other issues such as whether token holders are subject to Automatic Exchange of Information, or how to qualify economic advantages received by token holders, or even whether a mining plant represents a permanent establishment for tax purposes, is unclear. The aim of the present contribution is to provide an overview on how different jurisdictions – with a particular emphasis on Switzerland – have addressed the tax treatment of cryptocurrencies. This multi-jurisdictional study of the current situation includes the analysis of the tax treatment applicable to the mining, holding and transfer of tokens under both domestic law and tax treaties. Finally, along with their personal opinion, the authors propose alternative solutions to specifics issues that are as of today not regulated.