Kryptowerte und Digital Assets: CARF, DAC8 and the Italian rules

The gap in the CRS

The Common Reporting Standard was designed for accounts held with banks, custodians and funds. Kryptowerte und Digital Assets held in a wallet controlled by the owner, or held with an exchange or wallet provider that is not a financial institution in the sense of the CRS, escaped it. As holdings grew in the late 2010s, tax administrations recognized that a resident of Milan who kept bitcoin with a service provider in Zug or Lugano would not appear in the data that Switzerland sent to Italy. The OECD responded in 2022 and 2023 with the Crypto-Asset Reporting Framework (CARF), a separate standard for the automatic exchange of information on transactions in Kryptowerte und Digital Assets, adopted together with the amendments to the CRS described above.¹ CARF obliges crypto-asset service providers to identify their customers, to determine their tax residence and to report annually the aggregate values of exchanges between Kryptowerte und Digital Assets and fiat currencies, exchanges between different Kryptowerte und Digital Assets and certain transfers.²

For Lugano the subject is not abstract. Since the launch of Plan ₿ in March 2022, which Chapter I.I describes, the city has sought to attract service providers in the sector, and Chapter I.II sets out the Swiss supervisory framework for Kryptowerte und Digital Assets. A service provider in Lugano with Italian customers is now part of the same information network as a Lugano bank.

The Swiss implementation

The Federal Council adopted the dispatch on the implementation of CARF and of the CRS amendments on 19 February 2025, with the declared aim of closing gaps in tax transparency and ensuring equal treatment with traditional assets.³ On 6 June 2025 it adopted a separate dispatch on the list of partner states. The list comprised 74 states that it considered relevant to the market for Kryptowerte und Digital Assets, including all Member States of the European Union and the United Kingdom. The United States, China and Saudi Arabia were not on the list. The exchange with a partner state is to take place only if that state has an interest in it and meets the requirements of the standard, and a verification mechanism assesses compliance before the first transmission.⁴

Parliament approved the package in the autumn session of 2025. The National Council voted in September 2025 by 126 votes to 65 and by 128 votes to 65, following the Council of States, and rejected the proposed fines for negligent violations.⁵ The final vote took place on 26 September 2025. The amendments to the CRS took effect on 1 January 2026, while the exchange on Kryptowerte und Digital Assets is to be implemented with partner states at the earliest from 1 January 2027. The decision on the actual activation with partner states lies with Parliament, and no reporting obligations under CARF apply for 2026.⁶ The first exchange of data under CARF would therefore take place in 2028 for the year 2027, if the activation takes effect on 1 January 2027. This timetable depends on the decisions on activation still pending in the autumn of 2026.

Notes

1. OECD, International Standards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023 update to the Common Reporting Standard (Paris, 8 June 2023), approved by the Committee on Fiscal Affairs, https://www.oecd.org/tax/exchange-of-tax-information/crypto-asset-reporting-framework-and-amendments-to-the-common-reporting-standard.htm. ↩
2. OECD, International Standards for Automatic Exchange of Information in Tax Matters (above), CARF, Section II (reporting requirements) and Section IV (definitions of relevant transactions). ↩
3. "Bundesrat erweitert Informationsaustausch bei Kryptoregulierung", swissinfo.ch, 19 February 2025, https://www.swissinfo.ch/ger/bundesrat-erweitert-informationsaustausch-bei-kryptoregulierung/88898045. ↩
4. Swiss Federal Council, press release of 6 June 2025 on the dispatch concerning the list of 74 partner states for the automatic exchange of information on Kryptowerte und Digital Assets, https://www.admin.ch/de/newnsb/1QknKQ4iBGdl3Q7I4CL7b. ↩
5. Moneycab, 8 September 2025 (above). ↩
6. SIF, FAQ zum AIA über Kryptowerte (Update) (above): implementation "frühestens ab 1. Januar 2027"; decision on activation with partner states reserved to Parliament; no obligations in 2026. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of August 2025.