Bitcoin for a UK LLP

Checked 9 November 2026. Tax rates and rules change. Your accountant should confirm how they apply to your company.

This page is about United Kingdom companies. For the US, see C corporations, S corporations or LLCs. Other UK types: limited companies, LLPs.

How the LLP is taxed

A limited liability partnership is a separate legal person, so it can own bitcoin and sign agreements in its own name. For tax, HMRC's Partnership Manual says an LLP carrying on a trade, profession or business with a view to profit is treated as a partnership: its activities are treated as carried on by its members. The LLP files a Partnership Tax Return (SA800), and each member reports their share of profits and gains on their own return.

For chargeable gains, partners are generally treated as owning a fractional share of each partnership asset. HMRC's Capital Gains Manual covers partnerships from CG27000. When the LLP disposes of bitcoin, each member has a gain or loss on their share. Individual members pay Capital Gains Tax: GOV.UK gives rates of 18% within the basic rate band and 24% above it for gains from 6 April 2026, after the annual exempt amount. Corporate members pay Corporation Tax on their share.

The transparency condition

Section 2 of the Limited Liability Partnerships Act 2000 requires two or more persons associated for carrying on a lawful business with a view to profit. HMRC's manual says an LLP that stops carrying on a business with a view to profit loses tax transparency, with exceptions for a temporary cessation and a winding up that is not unreasonably prolonged. An LLP whose only activity is holding bitcoin raises a question: is that a business with a view to profit? If transparency is lost, the tax position changes significantly. Take advice before an LLP becomes mainly a holding vehicle.

Accounts

LLPs prepare and file accounts under the Companies Act 2006 as applied by SI 2008/1911, so the accounting choices are similar to those for companies: FRS 105 at historical cost where the LLP qualifies, or FRS 102 with bitcoin usually an intangible asset. See FRS 102.

Members' agreement

The members' agreement governs who can approve purchases, sales and signing, and how profits and gains are shared. It should also say how a retiring member's share is valued when the LLP holds bitcoin, because the price at the date of retirement can differ sharply from the accounts value. Adopt a treasury policy and record the members' approval. The UK funding page below is written mainly for limited companies, including director's loan accounts and the section 455 charge. An LLP uses members' capital and members' agreements instead, so ask your accountant how those rules apply before treating an advance as a loan or as capital. See funding a company bitcoin purchase.

Reporting by providers

An LLP is an entity user for the Cryptoasset Reporting Framework, so UK providers will ask for its legal name, address, registration number and, in some cases, controlling persons. See CARF.

Common questions

Does an LLP pay tax on its bitcoin gains?

Usually not itself. While it carries on business with a view to profit, it is transparent and the members are taxed on their shares.

What happens if the LLP only holds bitcoin?

It may not be carrying on a business with a view to profit, and HMRC says it would then lose transparency. Take advice.

Which return does the LLP file?

The Partnership Tax Return, SA800. Members report their shares on their own returns.

Sources

Primary sources only. Each link was checked on 9 November 2026. Rules change, so confirm the current version with your adviser.

1. HMRCPM131450: limited liability partnerships, taxation
2. legislation.gov.ukLimited Liability Partnerships Act 2000, section 2: incorporation document, with a view to profit
3. HMRCCapital Gains Manual CG27000: partnerships
4. GOV.UKCapital Gains Tax: what you pay it on, rates and allowances (18% and 24% from 6 April 2026)
5. HMRCPartnership Tax Return (SA800)
6. legislation.gov.ukSI 2008/1911: Limited Liability Partnerships (Accounts and Audit) (Application of Companies Act 2006) Regulations 2008
7. FRCFRS 102: The Financial Reporting Standard applicable in the UK and Republic of Ireland
8. FRCFRS 105: The Financial Reporting Standard applicable to the Micro-entities Regime
9. HMRCInformation you need to give to UK cryptoasset service providers