Digital Assets & Crypto

Tax and structural assessment of digital assets.

Crypto and digital asset structures require particular care: tax classification, documentation, bankability, custody, substance and transaction history must fit together.

Potential topics

Structure

Holding Structures

Assessment of private, corporate and foundation-related holdings of digital assets.

Documentation

Transaction History

Preparation of origin, acquisition, swaps, wallets and supporting evidence.

Banking

Bankability

Preparation of plausible materials for banks, service providers and compliance reviews.

Planning

Exit and Reorganisation

Structural preparation of disposals, contributions, relocations or governance changes.

When it becomes relevant

  • Digital assets are to be included in a company, foundation, DIFC Foundation or holding structure.
  • A sale, relocation, bank contact, custody change or tax review is planned.
  • Acquisition, swaps, wallet movements or source evidence are no longer easy to reconstruct.
  • Private and corporate wallets, exchanges, loans or funds flow have been mixed.
  • Banks, buyers, advisers or authorities expect robust source-of-wealth and source-of-funds materials.

Review questions

  • Which assets exist: coins, tokens, staking, DeFi positions, NFTs, participations or receivables?
  • Who controls wallets, private keys, exchanges and custody solutions?
  • How are acquisition, swaps, sales, lending, staking rewards or airdrops documented?
  • Do the assets economically belong to a person, company, foundation or another vehicle?
  • Which tax, regulatory, AML and banking questions arise before a transaction or structure change?

Outcome

  • Structured overview of assets, wallets, exchanges, ownership and transaction history.
  • Document list for tax advisers, bank, buyer, custodian or service provider.
  • Assessment which structure or documentation gaps should be closed before exit, relocation or bank contact.
  • Clear limits: no investment advice, no trading recommendations and no technical custody services.
Discuss digital asset topic