Hardware
Mining hardware qualifies as a productive business asset. Once placed in service, qualifying equipment can be depreciated through declining-balance depreciation under ESTV Circular A 1995, or in many cantons through an immediate write-off in the year of acquisition.
Up to 100% deductible in the year placed in service.
Eligible hardware includes ASIC miners, cooling systems, electrical infrastructure and network equipment directly used in mining. To qualify, the equipment must be acquired and actively placed in service before fiscal year-end.
Computer hardware and software ("Datenverarbeitungsanlagen") can be depreciated at 40% per year on the residual book value. The straight-line alternative is 20% per year on acquisition cost.
Several cantons (incl. Zurich, Bern, Schaffhausen, Zug, Basel-Stadt, Graubünden, Thurgau) permit an immediate write-off on movable business assets in the year of acquisition, depending on the canton down to 20 % residual value, and for IT/EDP equipment in some cantons down to a memorandum value of CHF 1. Unlike declining-balance, this can generate net operating losses that offset other corporate profit and carry forward up to seven years under Art. 67 DBG. For losses incurred from 2020 onwards, this period is expected to extend to ten years under the upcoming law change, at the latest from 1 January 2028.
An Example Calculation
In this illustrative scenario, a Swiss GmbH or AG generates CHF 500,000 in pre-tax annual profit and purchases CHF 300,000 of new qualifying mining hardware in fiscal year 2025. A combined corporate income tax rate of approximately 14.43% is assumed, reflecting the Swiss-wide average and including federal, cantonal and municipal taxes.
Assumptions and legal notes
Illustrative only. Figures assume a Swiss GmbH or AG, 2026 fiscal year, full eligibility for cantonal immediate write-off, and equipment placed in service before year-end. Combined corporate tax rate varies by canton: typically 11.66% (Lucerne) to 20.54% (Berne) with a Swiss-wide average of 14.43%. Not included: distribution-level taxation when paying out dividends, wealth tax on BTC holdings, capital tax. Actual results depend on canton of residence and individual circumstance. Not personal tax advice.
Hardware Cost CHF 300,000
Operating Costs
Mining does not end with hardware. Under Art. 58 and 59 DBG, all ordinary and necessary expenses incurred to operate a business are fully deductible in the year they are paid.
Fully deductible the year they're incurred.
This covers hosting fees, electricity, internet, hardware maintenance and repairs, insurance, accounting and professional services. Every recurring cost required to keep the hardware online and productive. Expenses must be documented in the tax year they are claimed.
Art. 58 and 59 DBG permit the deduction of any expense that is both ordinary (common in your business) and necessary (appropriate for operations). For mining, this covers the full operational stack required to keep the hardware online and productive. Taxes themselves also qualify as commercially justified expenses and are tax deductible.
WHAT BITKERN DELIVERS
You Own The Hardware. Bitkern Handles The Rest.
For the tax provisions above to apply, you need to own real, productive mining equipment that's placed in service during the tax year. Bitkern provides every layer of that: hardware, hosting, operations, and an exit path. No technical expertise required. No deployment hassle. No ongoing operations.
Hardware Sourcing & Procurement
Latest-generation ASICs sourced direct from manufacturer, purchased in your name or your GmbH or AGs name.
Deployment Worldwide
Placed in service in one of 20+ data centers across the U.S., Europe, Asia and beyond.
24/7 Monitoring
Continuous uptime management with a 98 % SLA. Issues identified and addressed before they impact hash rate.
Maintenance & Repairs
All hardware servicing, firmware updates and repair coordination handled by our technical team.
Monthly Statements & Reporting
Detailed reports on hash rate, earnings and operational metrics. Documentation ready for your accountant.
Optional Buyback Program
Want liquidity? We handle the secondary-market resale and provide depreciation-recapture data for clean exit.
Ready To Put Your Capital To Work?
INDEPENDENT TAX PARTNER
Tax Questions? Fineac Treuhand Tax Audit Has The Answers
Our independent partner Fineac Treuhand Tax Audit has a dedicated team of accountants and tax advisors with profound experience in the crypto business, who can support you on entity structure, depreciation strategy, and other specifics of your situation.
LEGAL NOTICE
Bitkern is not a tax advisor, certified fiduciary, financial service provider, or law firm. References to Art. 28, 58 and 67 DBG, the ESTV Circular A 1995, the ESTV working paper on cryptocurrencies, and the immediate-write-off practice of individual cantons describe general concepts of Swiss tax law only; their concrete application depends on canton of residence and the specific situation of the entity. The illustrative ~20 % combined corporate tax rate varies materially by canton (range roughly 11.85 %–21 %). Swiss federal and cantonal tax law and practice change frequently, and figures may not reflect the latest amendments. Before any tax-related decision, consult a qualified Swiss tax professional or licensed fiduciary. Independent advisors in our partner network act on their own behalf and are not representatives of Bitkern.