A Montblanc production mandate on the books in France.

What the business has signed.

A production mandate with Montblanc Capital Ltd, a company registered in Dublin, Ireland, under an Allocation Agreement. The business pays a mandate price at signature and in return holds a contractual right to the Bitcoin produced by a defined quantity of hashrate, on infrastructure Montblanc owns and operates, from the signature date to the April 2028 Bitcoin halving. Electricity is invoiced monthly in fiat and passed through at cost. Production is credited to the business daily on a public, signed ledger and settles on-chain each month to a hardware wallet the business controls. At term end a credit of 25% of the mandate price applies against a next-cycle mandate. The business acquires no hardware, no interest in specific machines and no share in Montblanc: it buys a service with a fixed term and a fixed price. Typical counterparties are a SAS, a SARL, a SA or an EURL subject to the impôt sur les sociétés, or an entreprise individuelle.

The documents the business receives.

Everything below is issued to the business in its own name and can be handed to you as it stands.

• —The proposal: contracted hashrate, mandate price, term, the projection the economics engine produced on the day, and the electricity rate.
• —The Allocation Agreement, signed digitally by both parties, with the Risk Disclosure Document it references.
• —Monthly electricity invoices in fiat, itemised, with running balances.
• —The public ledger: one signed entry per day for the business's wallet ID, publicly verifiable against Montblanc's published key, and one signed entry per monthly on-chain settlement with the Bitcoin transaction ID.
• —Monthly and annual statements of production, settlements and electricity, in BTC and in fiat at the day's rate.

The mandate price.

A payment at signature for a service delivered over a fixed term.

• —Companies at the impôt sur les sociétés keep accrual accounts: the payment is a charge constatée d'avance (compte 486), released to expense over the months of the mandate in line with the rattachement des charges à l'exercice. It is a prestation de services, not an immobilisation: no hardware is acquired.
• —Businesses taxed on a cash basis (bénéfices non commerciaux, art. 93 CGI) generally deduct the payment in the year it is paid. Entreprises individuelles under the régime micro deduct nothing item by item and are unlikely to be the right vehicle.
• —The expense is an ordinary charge déductible under art. 39 CGI, incurred in the interest of the business.

Electricity.

Invoiced monthly in fiat and passed through at cost. An ordinary charge of the period, with quantity, rate and period on each invoice.

The Bitcoin received.

Bitcoin is an actif numérique within art. L. 54-10-1 of the Code monétaire et financier. For companies, ANC regulation n° 2020-05 sets the accounting treatment of digital assets held.

• —Units produced under the mandate are a produit of the business at their market value on the day they are credited; that value becomes their cost of entry.
• —Held units are recorded under the accounts ANC regulation 2020-05 provides for digital assets, at cost, with any impairment recognised at year end. Unrealised appreciation is not a taxable produit.
• —On disposal the difference between proceeds and cost is an ordinary result taxed at the impôt sur les sociétés rate. For an individual the production of Bitcoin is taxed as bénéfices non commerciaux (art. 92 CGI); this brief addresses companies.
• —The daily ledger gives the quantity per day; the monthly statement gives the euro value at the day's rate.

VAT.

Montblanc Capital Ltd is established in Ireland and supplies a service to a business customer.

• —The place of supply is France (art. 259 CGI). The invoice carries no VAT and bears the mention autoliquidation; the business self-assesses the VAT (art. 283-2 CGI) and deducts it under the ordinary rules.
• —The Bitcoin itself is outside VAT: exchange of Bitcoin for fiat is exempt (CJEU, Hedqvist, C-264/14), and receiving produced units is not a supply by the business.

The renewal credit.

At term end the business holds a contractual right to a 25% reduction in the price of a next-cycle mandate. Nothing is paid out, and the right lapses if no next mandate is signed. It is generally read as a conditional price concession on a future contract, with no entry until it is used, rather than as income at term end. Your reading governs.

Substance.

The abus de droit procedure (art. L. 64 LPF) and the mini-abus de droit (art. L. 64 A LPF) scrutinise arrangements whose main purpose is a tax advantage. The mandate is a real service with a real cost: hardware procured and run for the term, electricity invoiced monthly, Bitcoin produced every day and settled monthly to a wallet the business controls, a fixed term. The business carries the economic risk of the Bitcoin price and of the network. Montblanc describes the mandate as a business expense that produces a business asset, and nothing else.

Points to settle with your client.

• —Impôt sur les sociétés or impôt sur le revenu, and the régime d'imposition.
• —The valuation of Bitcoin at the clôture and its presentation under ANC regulation 2020-05.
• —Custody: the business holds the keys to the wallet the Bitcoin settles to. Document the wallet as an asset of the business from the first settlement.
• —VAT registration and the reporting of the autoliquidation on the CA3.
• —The fiat value series for the produits: the monthly statement is prepared at the day's rate and can be re-based to the rate source your practice uses.
• —Montblanc does not provide tax advice, does not file returns and does not structure entities. This brief states what the contract is and how it generally presents; you map it to the rules that apply to your client.