Accounting for crypto-assets

A comparison with the Geneva foundation

Geneva, which has its own tradition of foundations, is the seat of many international foundations that pursue humanitarian, scientific and diplomatic purposes, often linked to the international organisations in the city. Whereas the Geneva foundation typically receives donations, pursues a charitable purpose and benefits from tax exemption, the Zug crypto foundation typically raises funds through a token sale, pursues the development of technology and is taxed as an ordinary entity. Beyond the legal form, the two have little in common. The contrast illustrates a broader theme of this book: Geneva's institutions grew out of international cooperation and philanthropy, while those of Zug grew out of commerce and the attraction of mobile capital.¹

Accounting for crypto-assets

The accounts of a crypto foundation raise questions that a conventional foundation does not face. Swiss accounting law requires assets to be valued at no more than their acquisition cost, with an exception for assets that have an observable market price on an active market. Crypto-assets that are traded on liquid markets can be valued at that price, whereas tokens without such a market must be valued at cost or at a lower value. The foundation's own tokens, which it keeps in its treasury, are a particular problem: although they may have a considerable market value, they represent above all the foundation's own obligations and prospects.²

The volatility of crypto markets makes the accounts of the foundations fluctuate widely. A foundation that held ether at the end of 2017 reported a large value for a holding that was worth a fraction of that amount a year later. The supervisory authority required the foundations to manage that risk, which led many to diversify their treasuries by converting part of their crypto-assets into francs, dollars or conventional investments. Among the largest foundations, which publish reports on their treasury policies, the Ethereum Foundation, for example, has published statements about its holdings of ether and fiat reserves and its policy of spending.³

Notes

1. Fundraiso Schweiz, "Charitable foundations in the canton of Geneva", fundraiso.ch (foundation database page, undated): 2,392 foundations and funding organisations in Geneva, one of the highest densities of foundations in Switzerland; many focus on development cooperation, humanitarian aid, peacebuilding, global health and scientific research. The figures of the Swiss Foundation Report for Geneva were not consulted. ↩
2. Swiss Code of Obligations (OR), Art. 960a para. 1 (on initial recognition, assets must be valued at no more than their acquisition or production cost) and Art. 960b para. 1 (in subsequent valuation, assets with a stock market price or another observable market price in an active market may be valued at that price at the balance sheet date, even if it exceeds the nominal value or the acquisition value), text as reproduced on swissrights.ch. The practice of auditors and of the supervisory authority is not covered by this citation. ↩
3. Ethereum Foundation, "EF Treasury Policy", 4 June 2025, blog.ethereum.org: annual operating spending set at 15 per cent of the treasury, reducing to a 5 per cent baseline over five years; fiat operating buffer of 2.5 years of expenses maintained by periodic sales of ether; ether reserves beyond the buffer deployed in staking and lending protocols. ↩

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 September 2025.