Workshop by Stéphanie Fuchs and Noëmi Kunz-Schenk on the occasion of the ISIS) seminar on May 22, 2022 entitled "The world of work on the move: tax and social security law challenges"
Note: This language version is an automatically generated translation. The text may therefore contain linguistic and terminological errors.
view in original language (German)Krypto AG is a technology company founded in Switzerland in February 2023. It develops a digital platform for the secure exchange of research data. Access to the platform and to certain additional features (such as data analysis tools or advanced storage options) is controlled via the company’s proprietary utility token, “Crypt.” The token is issued by Krypto AG.
The company currently has 7 full-time employees and pays a portion of its employees’ variable compensation in the form of Crypt. These tokens are not listed on any platform and are issued to employees after a one-year vesting period.
Four employees have been with Krypto AG since the “very beginning.” As part of its bonus program, they will be awarded 10,000 Crypt as of March 31, 2025, for their contributions as project participants from the outset. At the time of the award, there is no market price for the token yet, and the token is also not yet technologically available. The Token Generation Event (TGE) is not scheduled to take place until the following year (2026).
Since the company’s founding, the token has been valued at CHF 0.0004. In 2026, following the TGE, the token is expected to be valued at CHF 0.9 per Crypto.
The Blockchain Development Association (BDA) is a non-commercial association founded in Switzerland in September 2022 that develops a decentralized data processing platform. The association has two employees and relies primarily on service providers abroad to conduct its business operations. The platform is designed to store and process digital information securely, efficiently, and immutably. To do so, the BDA uses blockchain technology to manage data in a way that prevents manipulation and ensures traceability at all times.
Unlike traditional centralized databases, where a single party controls the stored information, BDA technology is based on a network of independent participants (nodes). These nodes verify and confirm all transactions and ensure that no unauthorized changes can occur. This not only enhances data security but also guarantees the transparency and integrity of the stored information.
To use the platform, the BDA issues its own token called the BDA Token. The token serves as a technical means of access to the services offered. For example, users can use the token to access specific storage and processing services within the network or to activate technical functions of the platform. Additionally, the token is intended to be used for governance purposes, such as voting on future developments. The token confers no participation rights under corporate law, no claims to distributions, and no ownership interest in the association.
The platform is intended to be particularly attractive to companies and organizations that rely on a reliable and transparent data infrastructure. Potential areas of application include financial services, logistics, identity management, or the exchange of sensor data in industrial networks.
In the early phases of the project, tokens were allocated as part of service agreements and funding rounds. Since they were not yet traded on an exchange, they had no official market value. Valuation was therefore based on the respective funding round or an internally determined value.
The Token Generating Event (TGE) took place in February 2025. The ICO is scheduled for July 2025.
A service provider, Tech Solutions GmbH, received an allocation of 2.5% of the total token supply in March 2021 based on an assumed value of USD 0.0002 per token.
Token classification: How should the token be classified?
Valuation of the tokens: How should the token be valued in each case?
Tax treatment for the recipient: How should the token allocation be treated for tax purposes? How is the difference in value between the allocation and the subsequent commencement of trading accounted for tax-wise?
Tax treatment for the BDA: Can the token allocation be deducted as a business expense, or how does it factor into cost-based taxation? What valuation is applied in this context?
Effects of changes in value:1. For the recipient (e.g., service providers or employees who have received tokens):1. How are subsequent price gains or losses treated for tax purposes? 2. Is the subsequent sale treated as a capital gain or as income?
The DataChain Association (DCA) is a non-commercial association founded in 2023 and based in Switzerland that is developing a decentralized data processing network. It now has 5 employees.
At the heart of the ecosystem is the DCA token. Within the platform, it serves as an access key to certain functions (e.g., data queries, validation) and as a unit of remuneration for those who provide data or contribute to the further development of the network. The token is not linked to any corporate rights but primarily fulfills a utility and incentive function within the protocol.
Following the successful Token Generating Event (TGE) in February 2025, the DCA decided to conduct an airdrop to promote the platform’s adoption and reward early supporters and active developers. A total of 7% of the total token supply is earmarked for the airdrop. Distribution will be based on the following criteria:
Rewards for active contributors**:**
Incentives for new users**:**
Token allocation will be staggered over several months to avoid market distortions. Additionally, recipients must gradually unlock their tokens over a 12-month vesting period. There is no token expiration or obligation to return tokens.
A large proportion of the recipients are located abroad—both developers and users are based in various jurisdictions, including the U.S., Germany, and Singapore.
CargoChain Association (CCA) is a non-commercial association based in Switzerland that was registered in the Commercial Register of the Canton of Zug on March 17, 2023.
Purpose and Vision:
DAO Integration:
Token Economy:
CargoChain Services AG (CCS AG) was founded in Switzerland in 2022.
It is responsible for:
CCS AG is compensated through service contracts with the association and receives its remuneration partly in CCT tokens and partly in fiat currency. Its employees also receive a portion of their compensation in CCT.
SmartRoute GmbH (SmartRoute) is a software company based in Zurich that developed the original algorithms for route optimization and tracking technologies.
Prior to the founding of CCA, SmartRoute was responsible for AI-based supply chain calculations to optimally coordinate truck and ship movements. The software was later transferred to CCS AG and subsequently to CCA.
Additional services provided by SmartRoute GmbH:
The board of directors and CEO functions of CCS AG are provided by SmartRoute. SmartRoute provides qualified personnel for leadership roles. Compensation is provided via a service agreement between CCS AG and SmartRoute GmbH in the form of cash and CCT tokens. This agreement covers strategic management, platform development, and operational management in the sense of outsourced management.
The platform enables logistics service providers to sell their available capacity directly to other companies via smart contracts.
Decentralized transport brokerage:
Real-time tracking and validation:
Tokenized network fees:
DAO governance for pricing mechanisms:
CCA plans a maximum issuance of 500 million CCT tokens, distributed across the following categories:
Helion Ventures AG (HV AG) is a private technology company headquartered in Switzerland. It develops highly specialized software solutions in the field of artificial intelligence and pursues an international growth strategy.
To retain key personnel in the long term, HV AG introduced a new employee participation program in 2025. Instead of traditional shares, it relies on tokenized equity rights registered on a private blockchain. The so-called HVT (Helion Venture Tokens) represent equity rights, i.e., shares in HV AG. The shares are not listed on a stock exchange.
The tokens are non-transferable, tied to the employment relationship, and are reversed upon termination. In certain cases, the program provides for a severance payment arrangement.
Allocation is in addition to the regular salary. The basis is an equity plan with individual allocation depending on position, start date, and performance. All tokens are subject to a four-year vesting period with a one-year cliff period. Valuation is performed annually using an internal model based on the estimated enterprise value.
