
Inserted by No I of the O of 26 Nov. 2025, in force since 1 Jan. 2026 (AS 2025 817).
English is not an official language of the Swiss Confederation. This translation is provided for information purposes only and has no legal force.
Section 1 Relevant Version of the OECD Commentarie
The version of the OECD commentaries on the Multilateral Model Competent Authority Agreement on the Automatic Exchange of Information in accordance with the Crypto-Asset Reporting Framework and on the Crypto-Asset Reporting Framework (CARF) that is relevant under Article 2b paragraph 2 AEOIA is that of 8 June 2023.
These commentaries may be accessed free of charge at: www.oecd.org > Topics > Taxation > Tax Transparency and International Co-operation > Related Publications > International Standards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023 Update to the Common Reporting Standard.
Section 2 Relevant Reporting Crypto-Asset Service
1 Reporting crypto-asset service providers that establish a personal connection with Switzerland pursuant to Article 3 or 50 DFTA are deemed to be resident in Switzerland for tax purposes pursuant to Article 12b paragraph 1 AEOIA. 2 Persons or entities required to file a tax return or a tax information return in Switzerland are subject to a duty to file tax information forms under Article 12b paragraph 1 AEOIA. The following are regarded as a tax return or a tax information return: a. the tax return for direct federal tax; b. the tax return for direct cantonal tax; c. certificates under Article 129 paragraph 1 letter c DFTA; d. certificates pursuant to the cantonal statutory provisions implementing Article 45 paragraph 1 letter c of the Tax Harmonisation Act of 14 December 1990. 3 Reporting crypto-asset service providers are deemed to have a branch office in Switzerland pursuant to Article 12b paragraph 1 AEOIA if they established an economic connection with Switzerland pursuant to Art
Para. 1 — SR 642.11 Para. 2 let. d — SR 642.14
Section 3 Further Details on Reporting Obligations
Reporting Swiss crypto-asset service providers may, in the event of the death of a person from a reporting state, treat that person’s estate as an estate with its own legal personality until the dissolution of the community of heirs. The estate is deemed to be a reportable person in that state or sovereign territory in which the deceased was last resident for tax purposes.
Section 4 Further Details on Due Diligence Obligat
1 Cases in which a business relationship with a crypto-asset user is established without the reporting Swiss crypto-asset service providers contributing to or being able to prevent the same are deemed to be exceptions under Article 12f paragraph 3 AEOIA. 2 These exceptions include in particular: a. a change in the crypto-asset user as a consequence of a court or official order; b. the creation of a beneficiary claim against a trust or similar legal entity on the basis of its deed of creation or the foundation deed.
1 If a business relationship is terminated before expiry of the deadlines in Article 12f paragraphs 1, 3 and 4 AEOIA and if the review of the business relationship by the reporting Swiss crypto-asset service provider has not been completed at the time of termination, the Reporting Swiss crypto-asset service provider may treat the crypto-asset user and the controlling person as non-reportable persons. 2 If a business relationship with a user is terminated after a change in circumstances and if the re-examination of the business relationship required by the change in circumstances has not been completed by the time of termination, the reporting Swiss crypto-asset service provider need not take the change in circumstances into account in the report.