A Montblanc production mandate on the books in Italy.

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 an S.r.l., an S.p.A., or a ditta individuale in regime ordinario or semplificato.

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 in regime ordinario apply the principio di competenza (art. 109 TUIR): the payment is a risconto attivo, released to cost over the months of the mandate. It is a prestazione di servizi, not an immobilizzazione: no hardware is acquired.
• —Businesses in regime semplificato (art. 66 TUIR) apply the cash principle and generally deduct the payment in the period it is paid. The regime forfettario allows no itemised deductions and is unlikely to be the right vehicle.
• —The cost is inerente to the business activity and enters the IRES base; for IRAP the classification of the cost in the conto economico determines its treatment.

Electricity.

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

The Bitcoin received.

Law 197/2022 (art. 1, paragraphs 126 to 147) defines cripto-attività and sets their tax treatment; the Agenzia delle Entrate's circolare 30/E of 27 October 2023 explains it. For companies the ordinary rules of business income apply.

• —Units produced under the mandate are a ricavo of the business at their market value on the day they are credited; that value becomes their cost.
• —Held units are assets of the business, classified under the OIC principles according to their intended use; year-end valuation differences are not taxed until realised, as paragraph 131 provides for enterprises.
• —On disposal the difference between proceeds and cost is business income or loss at the IRES rate, with IRAP where the item enters the IRAP base.
• —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 Italy (art. 7-ter DPR 633/72). The business integrates the invoice and accounts for the VAT under the reverse charge (art. 17, comma 2, DPR 633/72), deducting 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 abuso del diritto rule (art. 10-bis of Law 212/2000) 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.

• —Regime ordinario, semplificato or forfettario.
• —The OIC classification and year-end valuation of the Bitcoin held.
• —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, the integration of the invoices and their reporting.
• —The fiat value series for the ricavi: 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.