Bitcoin yield for a company: UK and US

Sources checked 10 November 2026. This page explains what is usually meant by yield on bitcoin, where any return comes from and what a company gives up to earn it. It quotes no rates, names no providers and makes no prediction about prices or returns. It is not investment, tax or legal advice and not a recommendation to lend, buy, sell or hold bitcoin. If anything here conflicts with a linked source, the source wins.

Short answer

Bitcoin does not pay anything by itself. Any return on it comes from someone else: a borrower paying to use it, a platform using it in ways the company cannot see, a buyer of an option, or users paying fees on a Lightning channel. To earn that return, the bitcoin almost always has to leave the company's 2 of 3 multisig, which replaces a risk the board controls with a promise from a counterparty. Celsius, BlockFi, Genesis and FTX all held customer crypto assets that customers could not withdraw when those firms failed. In the UK, HMRC does not treat the return as interest and a lend may itself be a disposal; in the US, returns are generally income.

Where a return on bitcoin can come from

Arrangement	Who pays the return, and why	What the company gives up
Lending to a counterparty	A borrower pays to use the bitcoin, for example to trade or to cover short positions.	Control of the coins. The company holds a promise to return an equivalent amount.
Platform yield accounts	The platform lends or invests the deposits and passes on part of what it earns.	Control, and usually any say over where the coins go next.
Rehypothecation	A lender or broker re-lends or pledges collateral it holds, keeping part of the income.	The certainty that the same coins will come back if the firm fails.
Wrapped bitcoin and DeFi	Bitcoin is swapped for a token on another blockchain and lent or pooled through smart contracts.	The coins themselves, in exchange for a token that depends on a custodian or bridge and on code.
Covered calls and other options	A buyer pays a premium for the right to buy the bitcoin at a set price.	Gains above that price, and often custody of the coins as margin with the venue.
Lightning routing fees	Users of the Lightning Network pay small fees to route payments through a channel.	Coins kept in hot channels on an always online node, not in cold multisig.
Products marketed as yield	Read the terms: the return will come from one of the rows above, or from new deposits.	Whatever the terms say, and sometimes more.

Our judgement, not a rule: if the terms do not explain who pays the return and why, treat that as an answer in itself.

Bitcoin has no native staking: it uses proof of work. An offer to stake bitcoin is usually one of the arrangements above under another name. HMRC notes that there is no statutory or legal meaning of lending and staking in this context and describes both as transfers of control of tokens to another person or platform.

Source: HMRC: Cryptoassets Manual CRYPTO61120: meaning of loan and staking.

Lightning fees are set by each node operator. The BOLT 7 specification describes a base fee and a proportional fee charged per transferred satoshi, so any income depends on payments actually being routed through the channel.

Source: Lightning BOLT specifications: BOLT 7: routing gossip, including fee_base_msat and fee_proportional_millionths.

The risks a company takes

Counterparty risk. The company is owed bitcoin by a firm that may not be able to pay it back.
Custody leaves the multisig. The company's own keys no longer control the coins, so none of the controls in the treasury policy apply to them.
Insolvency. If the firm fails, the company may be an unsecured creditor waiting for a court process, not an owner taking its coins back.
Hidden reuse. The firm may lend or pledge the coins again, so the company's exposure includes people it has never heard of.
Smart contract and bridge risk for wrapped bitcoin and DeFi, and operational risk for hot Lightning nodes.
Tax and accounts. A lend may be a disposal, and the asset on the balance sheet may change from bitcoin to a receivable.

For the opposite trade, using bitcoin as collateral for a loan, see borrowing against company bitcoin, which covers rehypothecation from the borrower's side.

What happened at Celsius, BlockFi, Genesis and FTX

Firm	What the regulator or prosecutor said
BlockFi	In February 2022 the SEC charged BlockFi Lending with failing to register the offers and sales of its retail crypto lending product. BlockFi agreed to pay a $50 million penalty to the SEC and a further $50 million to 32 states.
Genesis and Gemini Earn	In January 2023 the SEC charged Genesis and Gemini over the Gemini Earn lending program. The SEC said that in November 2022 Genesis stopped Gemini Earn investors withdrawing their crypto assets because it lacked sufficient liquid assets to meet withdrawal requests. At the time Genesis held about $900 million of assets from 340,000 Gemini Earn investors.
Celsius	The SEC charged Celsius and its founder in July 2023, saying Celsius offered an Earn Interest Program until it effectively halted its platform on 12 June 2022. In May 2025 the founder was sentenced to 12 years in prison; prosecutors said he misrepresented the safety of Celsius's yield generating activities.
FTX	The SEC charged FTX's founder in December 2022, alleging the undisclosed diversion of FTX customers' funds to Alameda Research. In March 2024 he was sentenced to 25 years; the Department of Justice said he misappropriated billions of dollars of customer funds.

Source: SEC: Press release 2022-26: BlockFi agrees to pay $100 million in penalties over its crypto lending product (14 February 2022), SEC: Press release 2023-7: SEC charges Genesis and Gemini over the Gemini Earn lending program (12 January 2023), SEC: Press release 2023-133: SEC charges Celsius Network and its founder (13 July 2023), US Attorney, SDNY: Founder of Celsius sentenced to 12 years for fraud and market manipulation (8 May 2025), SEC: Press release 2022-219: SEC charges Samuel Bankman-Fried with defrauding investors in FTX (13 December 2022), US Department of Justice: Samuel Bankman-Fried sentenced to 25 years (28 March 2024).

Our judgement, not a rule: in each case customers believed their assets were safe and earning a return. The common lesson is that a return on bitcoin is payment for taking someone else's risk.

Board and policy questions

Does the treasury policy allow any bitcoin to leave the company's multisig for a return? If it is silent, the answer should be no until the board decides.
Who pays the return, and what does the firm do with the coins? Is reuse or rehypothecation allowed?
Is the company an owner or a creditor if the firm fails? What do the terms and the insolvency law of the firm's country say?
What is the most the company could lose, and could it carry on if it lost all of it?
How quickly can the coins come back, and can the firm suspend withdrawals?
What is the tax and accounting effect, confirmed by the company's adviser and auditor before any transfer?
Who approves, who monitors, and what would make the company recall the coins?

See directors' duties and custodian due diligence, which asks the same questions of anyone holding company bitcoin.

Choose your country for tax and accounts.

United KingdomGo to United States

UK: Corporation Tax

HMRC does not consider the return on lending cryptoassets to be interest for tax purposes, because it does not consider cryptoassets to be currency or money. For a company, HMRC says it does not expect lending or staking tokens to be a loan relationship, so the loan relationship rules do not apply. How the return is taxed depends on whether it is capital or revenue: a revenue return outside a trade falls within the miscellaneous income rules in sections 979 to 981 CTA 2009, charged on the pound sterling value of the tokens received.

Source: HMRC: Cryptoassets Manual CRYPTO61110: DeFi lending and staking, introduction (the return is not interest), HMRC: Cryptoassets Manual CRYPTO61412: Corporation Tax, taxing provisions (not a loan relationship), HMRC: Cryptoassets Manual CRYPTO61413: Corporation Tax, amount chargeable.

The lend itself may be a disposal. HMRC says the question is whether beneficial ownership passes to the borrower or platform, which depends on the contract: if the recipient can deal with the tokens as it wants, that is a strong indicator that it has beneficial ownership, and the lender will have disposed of them. HMRC also says lending tokens may amount to a trade.

Source: HMRC: Cryptoassets Manual CRYPTO61620: chargeable gains, making a DeFi loan (beneficial ownership), HMRC: Cryptoassets Manual CRYPTO61130: making a DeFi loan.

UK: accounts

Our judgement, not a rule: the same contract terms that decide the tax question will matter to the accounts, because a company that has passed ownership of its bitcoin may hold a right to receive bitcoin rather than bitcoin. Agree the treatment with your accountant before any transfer. See company tax on bitcoin.

United StatesGo to United Kingdom

US: federal tax

The IRS treats digital assets as property, not currency. Gross income under 26 U.S.C. 61 means all income from whatever source derived, so a return received in bitcoin or dollars is generally income. In Revenue Ruling 2023-14 the IRS held that staking rewards on a proof of stake blockchain are included in gross income when the taxpayer gains dominion and control over them; bitcoin itself has no staking, but the ruling shows the IRS approach to rewards paid in crypto.

Source: IRS: Digital assets: property for tax purposes, and the digital asset question, govinfo: 26 U.S.C. 61: gross income defined, IRS: Revenue Ruling 2023-14: staking rewards included in gross income (PDF).

Our judgement, not a rule: whether lending bitcoin is itself a sale or exchange depends on the terms, and we have not found IRS guidance that settles it for crypto loans. Get written advice before lending.

US: accounts

ASU 2023-08 requires crypto assets within its scope to be measured at fair value. It does not set out how to account for bitcoin that has been lent, so agree with your auditor whether lent bitcoin stays on the balance sheet or becomes a receivable.

Source: FASB: ASU 2023-08, Crypto Assets (Subtopic 350-60): fair value measurement (PDF).

Both countries

Common questions

Is a small allocation to yield a reasonable compromise?

That is for the board to decide with advice. What this page can say is that whatever amount leaves the multisig takes on the counterparty and insolvency risks above, whatever its size.

Can the company earn a return without the bitcoin leaving its multisig?

Not from the arrangements on this page. Each one needs the coins, or control of them, to move somewhere else, at least for a time.

Is a return quoted as a percentage a promise?

No. HMRC notes that the return may be described as interest by the people involved, but it does not treat it as interest for tax. And a firm that cannot repay cannot pay any return either.

Common mistakes

Treating a yield account as a bank deposit.
Not reading whether the firm may reuse the coins.
Moving bitcoin out of the multisig without a board decision.
Assuming the return is interest for UK tax.
Forgetting that the lend itself may be a disposal.

Sources

Primary sources only. Each link was checked on 10 November 2026. Rules change, so confirm the current version with your adviser.

Education, not advice.

This is general information and education only. It is not financial, investment, tax, accounting, legal or regulatory advice, and it is not a recommendation to buy, sell or hold bitcoin or any other asset. It does not take account of your circumstances or those of your company. You must obtain your own official professional advice to confirm this information is correct before acting on it.

Rules change. This information is correct to our understanding at the last-reviewed date, but it may be incomplete or out of date, and official sources take precedence. Bitcoin is volatile. A company that buys it could lose some or all of the money it puts in.

Using this site does not create an adviser or client relationship. IoT Financial is not authorised or regulated by the Financial Conduct Authority (FCA) and is not registered with the US Securities and Exchange Commission (SEC) as an investment adviser. Read the full disclaimer.