Switzerland is preparing to introduce the Automatic Exchange of Information on Crypto Assets, a new international reporting framework that will bring crypto assets further into the global tax transparency system.
The new rules are based on the OECD’s Crypto-Asset Reporting Framework, known as CARF, and are intended to close the transparency gap between traditional financial assets and crypto assets. While banks and financial institutions have already been subject to automatic exchange of information rules for several years, many crypto assets have until now been held outside the traditional banking system, often through exchanges, brokers or wallet providers.
According to the Swiss State Secretariat for International Finance, Switzerland has expressed its political intention to implement the new framework. However, the rules will not apply before 1 January 2027 at the earliest.
From Bank Accounts to Crypto Assets
The existing automatic exchange of information regime mainly applies to traditional financial accounts, such as bank accounts and securities accounts. The crypto market developed differently. Investors could hold and transfer digital assets through platforms and wallets that were not always covered by the same reporting standards.
This created a practical gap in international tax transparency. The new crypto AEOI framework is designed to address that gap by requiring certain crypto service providers to collect and report tax-relevant information. That information may then be exchanged automatically between tax authorities of participating jurisdictions.
In simple terms, crypto assets are moving closer to the same reporting environment that already applies to bankable assets.
Private Clients
For private investors, the main point is clear: crypto assets should no longer be viewed as sitting outside the tax reporting system.
Clients holding crypto assets should review whether their holdings and related income have been properly declared in their country of tax residence. This may include not only the value of the crypto assets themselves, but also trading gains, staking income, lending income, mining income, airdrops, token swaps and assets held through companies, trusts or foundations.
The issue is particularly important for clients with a cross-border profile. A Swiss resident, an Israeli resident, a UK resident or an EU resident may each be subject to different tax rules. Where crypto assets were not properly reported in the past, early legal and tax advice may be important before information begins to be exchanged automatically.
Trustees, Fiduciaries and Family Offices
The new framework is also relevant for trustees, fiduciaries and family offices.
Where crypto assets are held through a company, trust, foundation or other structure, the reporting analysis may be more complex. It may be necessary to determine who owns or controls the assets, who controls the relevant wallet or exchange account, and whether settlors, beneficiaries, shareholders or other controlling persons may be reportable.
The introduction of crypto AEOI will likely increase the importance of proper documentation. Structures holding crypto assets should maintain clear records of ownership, control, transaction history, source of funds and tax reporting.
For fiduciaries and trustees, this is not only a tax issue. It is also a governance and compliance issue.
Preparing Before 2027
Although the Swiss rules are not expected to apply before 2027, clients should use the time available to prepare.
A practical review should include a full overview of crypto holdings, wallets and exchange accounts, together with historical transaction records. Clients should also review whether their crypto assets have been correctly reported for tax purposes and whether any structure holding crypto assets is properly documented.
Where past reporting was incomplete, voluntary disclosure may need to be considered, depending on the relevant jurisdiction and timing.