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Cryptocurrency: Automatic Information Exchange

Cryptocurrency: Automatic Information Exchange

Cryptocurrency Taxation for Individuals in Switzerland: Automatic Information Exchange

Holding and trading cryptocurrencies raises complex tax questions in Switzerland. Individuals owning digital assets must know their reporting obligations, particularly within the framework of the Automatic Exchange of Information (AEOI). This international mechanism, in which Switzerland actively participates, aims to combat tax evasion by allowing tax authorities to exchange information on taxpayers' financial accounts.

Swiss Legal Framework for Cryptocurrencies

In Switzerland, cryptocurrencies are treated as assets and not as official currencies. FINMA generally classifies them as payment, utility or investment tokens depending on their nature. For tax purposes, the Federal Tax Administration (FTA) treats cryptocurrencies as movable assets. The tax treatment rests on several fundamental pillars:

  • For individuals, capital gains realised on cryptocurrencies held as private assets are in principle tax-exempt
  • Cryptocurrencies are subject to wealth tax and must be declared in the annual tax return
  • Mining and staking generate taxable income
  • Active trading activity may be classified as professional activity, rendering gains taxable

Principles of the Automatic Exchange of Information

The Automatic Exchange of Information (AEOI) is an international mechanism adopted by Switzerland in 2017 to combat tax evasion. This system allows tax authorities in participating countries to automatically exchange information on financial accounts held by non-resident taxpayers.

The AEOI works in several steps:

  • Financial institutions collect information on accounts held by foreign tax residents
  • This information is transmitted to the national tax authority (in Switzerland, the FTA)
  • The FTA then transmits this data to the tax authorities of partner countries
  • In return, Switzerland receives similar information about Swiss residents holding accounts abroad

Switzerland currently exchanges information with more than 100 partner jurisdictions under the AEOI, based on the Common Reporting Standard (CRS) developed by the OECD.

Application of AEOI to Cryptocurrencies

Type of Actor/Entity Subject to Current AEOI? Subject to Future OECD CARF? Remarks
Regulated Swiss centralised exchangeYes (reporting financial institution)YesData transmitted on foreign residents
Foreign centralised exchange (AEOI country)Depends on classification in country of originYesData transmitted to FTA on Swiss residents
Institutional custody serviceYes (generally)YesCrypto banks subject to ordinary AEOI rules
Crypto investment fundYes (investment entity)YesTreated as traditional fund
Non-custodial wallet (MetaMask, Ledger)NoUncertainDecentralised blockchain = no reporting institution
DeFi protocols (Uniswap, Aave)NoUncertainNo identifiable reporting entity

Evolution: The OECD Crypto Asset Reporting Framework (CARF)

The OECD has developed the Crypto Asset Reporting Framework (CARF), a new international standard for automatic information exchange specifically designed for digital assets. This framework, whose adoption is planned in many countries from 2026–2027, will impose reporting obligations on digital asset service providers (DASPs) similar to those of financial institutions under the standard AEOI.

CARF will notably cover:

  • Centralised exchanges offering crypto/fiat or crypto/crypto conversion services
  • Custodial wallet providers
  • Certain stablecoin issuers

Reporting Obligations for Swiss Residents

Irrespective of the AEOI, Swiss tax residents have reporting obligations concerning their cryptocurrencies. These obligations apply even if the digital assets are not directly covered by the automatic exchange of information:

  • Declare the value of cryptocurrencies on 31 December in the wealth tax
  • Declare income generated by cryptocurrencies (mining, staking, lending)
  • In the case of professional trading, declare capital gains as self-employment income
  • Keep complete documentation of all transactions

Frequently Asked Questions about AEOI and Cryptocurrencies in Switzerland

Does Switzerland exchange crypto account data with other countries?

Centralised Swiss exchanges subject to the AEOI transmit data on foreign residents' accounts. Switzerland exchanges with more than 100 partner jurisdictions. The OECD is currently developing the Crypto Asset Reporting Framework (CARF), which will extend the AEOI specifically to digital assets, with implementation expected from 2026–2027 in several countries.

Is my account on a foreign exchange reported to the Swiss authorities?

If the foreign exchange is established in a country participating in the AEOI and qualifies as a reporting financial institution, your data may be transmitted to the FTA. Major global platforms (Coinbase, Kraken, Binance depending on jurisdiction) are progressively being integrated into information exchange systems.

Are non-custodial wallets covered by the AEOI?

Not directly. Decentralised blockchains and non-custodial wallets (MetaMask, Ledger, etc.) do not constitute reporting financial institutions under the current AEOI. However, the OECD's future CARF could impose obligations on wallet providers that facilitate exchanges.

What should I do if a foreign exchange has already communicated my data to the Swiss authorities before I declared?

If the authorities have already received information about your accounts, you can no longer benefit from non-punishable voluntary disclosure. The ordinary tax assessment procedure will apply with potential penalties. PBM Avocats can represent you in this procedure and defend your interests before the tax authorities.

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