Cross-Border Tax Ramifications of Swiss Blockchain Foundations: How Can a Rock Dam the Sea?

In this article, the authors explore some international tax concerns revolving around Swiss blockchain foundations, with a focus on the risk of triggering a permanent establishment where the resources working for such organizations are located and the need to determine an appropriate remuneration, in compliance with articles 5 and 7 of the OECD Model. In doing so, the authors envisage the need for revisiting the applicable tax framework, more in line with decentralized ways of working.