Bitcoin in corporate treasury: practical aspects

More and more Swiss companies are considering holding Bitcoin — or other crypto-assets — as part of their treasury. The reasons vary: diversification, strategic exposure, management of excess liquidity. But before the reasons come the practical aspects: how it is accounted for, how it is valued, which taxes it touches, how it is held in custody and who decides. Holding Bitcoin in a company is not like holding it in a personal wallet: it enters a system of accounting, tax and governance rules. Here is what you need to know.

Accounting: an asset to be classified

Bitcoin held in treasury is an asset to be recorded on the balance sheet under the Code of Obligations. Being neither cash nor a receivable, it must be treated as a distinct balance sheet item, typically among the assets, with a prudent valuation consistent with the principles of orderly presentation of the accounts.

The delicate point is the valuation. Swiss accounting law is founded on the principle of prudence: assets must not be overstated. In practice this often leads to valuing at the lower of acquisition cost and market value, recognising losses but not necessarily unrealised gains. Bitcoin’s volatility makes this choice significant: the valuation policy must be defined and applied consistently, and documented in the notes.

Taxes: where it has an impact

Holding and moving crypto within a company touches several taxes.

• Profit tax: realised capital gains on the sale contribute to the company’s taxable profit; losses are deductible according to the ordinary rules. Value adjustments follow the accounting treatment.
• Capital tax: the crypto-assets held fall within the company’s taxable equity, with the applied valuation.
• VAT (MWST): the exchange of Bitcoin as a means of payment is generally treated as an excluded/out-of-scope transaction, but the analysis depends on the concrete use (payment, services rendered, trading activity). It must be checked case by case, also in relation to the liability threshold of CHF 100,000 of turnover.
• Withholding tax: merely holding Bitcoin does not in itself generate returns subject to withholding tax, but the overall structure must be assessed.

The applicable rules on crypto are evolving and cantonal practice can vary: the figures and treatments must be confirmed in the specific case, without taking for granted the analogy with other assets.

Custody: who controls the keys

The fundamental principle applies in a company too: whoever controls the private keys controls the value. The company must decide whether to:

• rely on a professional custodian (the simpler solution in terms of security and continuity, with costs and counterparty risk);
• manage its own self-custody (greater control, but full responsibility for security, backups and signing procedures).

In both cases, procedures are needed that do not depend on a single person: the loss of a key is the loss of the value, and unsupervised access is a direct asset risk. Custody must be treated as part of the internal control system.

Governance: a decision for the board

Holding Bitcoin in treasury is a strategic decision that falls to the administrative body. In light of the duty of diligence, the board should:

• define a written policy (how much to hold, over what horizon, with what risk limits);
• establish who may operate and with what authorisations and dual signatures;
• provide for the accounting treatment and controls;
• document the decision in the minutes.

Holding a volatile asset without a governance framework exposes the directors to challenges: the resolution and the policy are also a safeguard.

The correct sequence

First you define the objective and the risk appetite; then you set the policy and governance; then you choose the custody; finally you set up the consistent accounting and tax treatment. Buying first and sorting it out afterwards is the path that generates the most costly problems, at year-end closing and during audits.

How SIH ONE approaches the topic

SIH ONE deals with structuring and advice: setting up the accounting and tax treatment, designing the treasury policy and governance, coordinating the VAT and tax aspects. Where professional custody or activities subject to authorisation are needed, the regulated activities go through authorised partners. The aim is for Bitcoin in treasury to be a managed choice, not an improvised exposure.

This content is informative and does not constitute tax, accounting or legal advice. The figures and treatments must be verified in the specific case.

Are you considering Bitcoin in treasury and want to set it up well from the start? Let’s talk about it: we define the accounting and tax treatment and the governance, with the right partners where custody is needed.