Company tax on bitcoin in the UK and the US

Last checked 29 October 2026. Tax rules and official guidance change. Your accountant should confirm how they apply to your company. If anything here conflicts with the linked source, the source wins.

The UK and the US tax a company's bitcoin in different ways, but both look at what happens when the company disposes of it. Choose your country.

Which tax rules apply

HMRC's Cryptoassets Manual sets out an order of questions for companies. The answer decides which part of the Corporation Tax rules applies. For a company that buys bitcoin and holds it in its treasury, HMRC's guidance points to the chargeable gains rules.

Source: HMRC: CRYPTO40150: Is the business trading in cryptoassets?, HMRC: CRYPTO41150: Corporation Tax, intangible fixed assets, HMRC: CRYPTO41050: Corporation Tax, cryptoassets are not money or currency, HMRC: CRYPTO41100: Corporation Tax, loan relationships, HMRC: CRYPTO41200: Corporation Tax on chargeable gains, introduction.

Because HMRC does not treat bitcoin as currency, the foreign currency rules for companies, the Disregard Regulations and designated currency elections do not apply to it. A loan of money that is secured on bitcoin is a different thing: the loan itself is a loan relationship.

Source: HMRC: CRYPTO41050: Corporation Tax, cryptoassets are not money or currency, HMRC: CRYPTO41100: Corporation Tax, loan relationships.

What counts as a disposal in the UK

Source: HMRC: CRYPTO41250: Corporation Tax on chargeable gains, what counts as a disposal, HMRC: CRYPTO41500: Corporation Tax on chargeable gains, loss of private keys, HMRC: CRYPTO41550: Corporation Tax on chargeable gains, theft.

This is one reason the site recommends a 2 of 3 multisig for company holdings: HMRC gives no tax relief for stolen coins, so preventing loss matters more than any relief.

Working out the gain: pooling

Bitcoin is normally pooled. All the company's bitcoin sits in one pool with a single pooled cost, and each disposal takes a proportion of that cost. Other cryptoassets each have their own pool. HMRC's own example:

Source: HMRC: CRYPTO41350: Corporation Tax on chargeable gains, pooling and the same day and ten day rules.

Source: HMRC: CRYPTO41350: Corporation Tax on chargeable gains, pooling and the same day and ten day rules.

Allowable costs

HMRC lists costs that can be deducted in working out the gain. They include the price paid, transaction fees paid to have a transaction added to the blockchain, and certain professional costs, such as fees for drawing up a contract or valuing the coins. Some exchange fees can also be allowable. Keep the evidence for each one.

Source: HMRC: CRYPTO41300: Corporation Tax on chargeable gains, allowable costs.

Losses

A disposal for less than its pooled cost gives an allowable loss, which must be reported to HMRC. There are special rules for disposals to connected persons. If the coins have become of negligible value, a negligible value claim can be made, and HMRC says it is made for the pool as a whole.

Source: HMRC: CRYPTO41400: Corporation Tax on chargeable gains, losses, HMRC: CRYPTO41450: Corporation Tax on chargeable gains, negligible value claims.

The rate of tax

A chargeable gain is added to the company's other taxable profits and taxed at its Corporation Tax rate. From 1 April 2023, the main rate is 25% on profits over £250,000 and the small profits rate is 19% on profits of £50,000 or less. Marginal Relief can reduce the rate in between. The limits are divided by the number of associated companies, and close investment holding companies cannot claim Marginal Relief.

Source: GOV.UK: Corporation Tax rates and allowances, GOV.UK: Corporation Tax: Marginal Relief.

Records and sterling values

Each transaction must be converted into pounds at the time it happens. HMRC expects a reasonable, consistent method that the company records and keeps to. For each transaction, keep the date and time, the type, the number of units, the sterling value and how it was worked out, fees, and the running pool.

Since 1 January 2026, UK cryptoasset service providers must collect information about their users for the Cryptoasset Reporting Framework and report it to HMRC. A company will be asked for its details and those of its controlling persons. If you do not provide them, a penalty can apply and the provider can refuse to act for you.

Source: HMRC: CRYPTO40100: Conversion to sterling and accountancy, HMRC: CRYPTO49000: Cryptoasset Reporting Framework, HMRC: IEIM8000050: Cryptoasset Reporting Framework, commencement.

The accountant's corner has a recording checklist and export tips.

How this sits with the accounts

Accounting and tax are separate questions. Under FRS 105, the micro entity standard, bitcoin is held at historical cost with no fair value movements. The chargeable gains rules look at disposals. A change in value shown in the accounts is not itself a disposal. The FRS 105 accounting page explains the accounts side.

Source: FRC: FRS 105: The Financial Reporting Standard applicable to the Micro-entities Regime, HMRC: CRYPTO41200: Corporation Tax on chargeable gains, introduction.

UK points to check with your adviser

• Whether your company could be trading, or could hold bitcoin as an intangible fixed asset. HMRC expects both to be uncommon for a treasury holding, but the facts of each company decide.
• Groups: transfers between group companies and connected persons have their own rules, which this page does not cover.
• VAT: HMRC describes its VAT view on cryptoassets as provisional. See taking bitcoin as payment.
• Exchange traded products that hold or track bitcoin are taxed differently from bitcoin held directly. See the accountant's corner.

Source: HMRC: CRYPTO45000: VAT and cryptoassets (HMRC calls its view provisional).

This section covers C corporations, which file Form 1120. Other business structures, such as S corporations and partnerships, are taxed differently and are not covered here.

Property, not currency

The IRS says that for US tax purposes digital assets are property, not currency, and that general tax principles for property transactions apply. Every transaction must be reported in US dollars, using a value worked out in a reasonable, consistent way. Form 1120, the corporate return, asks whether the company had any digital asset transactions during the year.

Source: IRS: Digital assets, IRS: Notice 2014-21: virtual currency is treated as property for federal tax purposes, IRS: Frequently asked questions on virtual currency transactions.

What counts as a disposal in the US

Source: IRS: Digital assets, IRS: Notice 2014-21: virtual currency is treated as property for federal tax purposes.

Federal and state rates

A corporation figures its federal tax at 21% of taxable income. There is no lower federal rate for a corporation's capital gains: gains are part of taxable income. State corporate taxes are separate and vary widely. For example, California taxes most corporations, other than banks and financial corporations, at 8.84%. Check every state where the company files.

Source: IRS: Publication 542, Corporations: 21% rate and capital losses, California Franchise Tax Board: Business tax rates.

Capital losses

IRS Publication 542 says "A corporation can deduct capital losses only up to the amount of its capital gains." A net capital loss is generally carried back 3 years and then forward 5 years, and is treated as a short term loss in those years. This is stricter than the UK, so a large loss may take years to use.

Source: IRS: Publication 542, Corporations: 21% rate and capital losses.

Cost basis, wallet by wallet

Basis is normally what the company paid, plus allowable costs. From 1 January 2025, the rules for identifying which units were sold apply wallet by wallet or account by account, not across all the company's holdings. Within a wallet or account, units are treated as sold oldest first unless the company makes a valid specific identification of the units sold, no later than the time of sale.

Revenue Procedure 2024-28 gave a safe harbour for allocating unused basis to each wallet and account as at 1 January 2025. Notice 2025-7 gave temporary relief on how units held at a broker can be identified. Units held in the company's own multisig are not covered by that relief.

Source: IRS: Revenue Procedure 2024-28: allocating unused basis to wallets and accounts (PDF), IRS: Notice 2025-7: identifying digital asset units held by a broker (PDF).

Form 1099-DA

Brokers report gross proceeds from digital asset sales on Form 1099-DA, and in some cases basis. For 2025, the requirements generally apply to US brokers. Basis is only reported for "covered" units, broadly those bought from 2026 onwards in the same account at that broker. Units transferred in to a broker, for example from the company's own multisig, are not covered, so the broker will not report their basis. Brokers do not have to file the form for exempt recipients, which generally include corporations. Whether or not a Form 1099-DA arrives, the company must report all its gains and losses.

Source: IRS: Understanding your Form 1099-DA, IRS: Instructions for Form 1099-DA (2026): covered securities, basis reporting and exempt recipients, IRS: About Form 1099-DA, Digital Asset Proceeds From Broker Transactions.

Records

For each unit, keep the date acquired, the dollar cost and fees, the wallet or account it sits in, and for each disposal the date, the dollar value received and the units identified. Keep the board approval with each sale. Build these records from the first purchase, because a broker's form may not show the basis for coins the company moved in from its own wallet.

Source: IRS: Digital assets, IRS: Notice 2014-21: virtual currency is treated as property for federal tax purposes, IRS: Revenue Procedure 2024-28: allocating unused basis to wallets and accounts (PDF).

How this sits with the accounts

Under US GAAP, ASU 2023-08 requires in scope crypto assets, including bitcoin, to be measured at fair value with changes in net income. It is effective for fiscal years beginning after 15 December 2024. The tax rules above look at disposals, so the accounts and the tax figures can differ, and your accountant reconciles the two. For the UK accounts side, see the FRS 105 page.

Source: FASB: ASU 2023-08, Intangibles: Goodwill and Other, Crypto Assets (Subtopic 350-60).

US points to check with your adviser

• State tax: which states the company files in, and how each treats gains.
• Lost or stolen coins: no IRS guidance found by this site settles the treatment for a corporation.
• Wash sales: whether the wash sale rule applies to bitcoin is not settled, and a bill would change it. See selling or rebalancing.
• Business structure: S corporations, partnerships and LLCs taxed as partnerships are not covered here.

Read next

• UK company bitcoin accounting under FRS 102 and FRS 105
• Accountant's corner: rules side by side, records and exports.
• Selling or rebalancing: how the policy and the tax rules meet.
• Sizing guide: the accounting notes.

Sources

Primary sources only. Each link was checked on 29 October 2026. Rules change, so confirm the current version with your adviser.

1. HMRCCRYPTO40150: Is the business trading in cryptoassets?
2. HMRCCRYPTO41150: Corporation Tax, intangible fixed assets
3. HMRCCRYPTO41050: Corporation Tax, cryptoassets are not money or currency
4. HMRCCRYPTO41100: Corporation Tax, loan relationships
5. HMRCCRYPTO41200: Corporation Tax on chargeable gains, introduction
6. HMRCCRYPTO41250: Corporation Tax on chargeable gains, what counts as a disposal
7. HMRCCRYPTO41500: Corporation Tax on chargeable gains, loss of private keys
8. HMRCCRYPTO41550: Corporation Tax on chargeable gains, theft
9. HMRCCRYPTO41350: Corporation Tax on chargeable gains, pooling and the same day and ten day rules
10. HMRCCRYPTO41300: Corporation Tax on chargeable gains, allowable costs
11. HMRCCRYPTO41400: Corporation Tax on chargeable gains, losses
12. HMRCCRYPTO41450: Corporation Tax on chargeable gains, negligible value claims
13. GOV.UKCorporation Tax rates and allowances
14. GOV.UKCorporation Tax: Marginal Relief
15. HMRCCRYPTO40100: Conversion to sterling and accountancy
16. HMRCCRYPTO49000: Cryptoasset Reporting Framework
17. HMRCIEIM8000050: Cryptoasset Reporting Framework, commencement
18. FRCFRS 105: The Financial Reporting Standard applicable to the Micro-entities Regime
19. HMRCCRYPTO45000: VAT and cryptoassets (HMRC calls its view provisional)
20. IRSDigital assets
21. IRSNotice 2014-21: virtual currency is treated as property for federal tax purposes
22. IRSFrequently asked questions on virtual currency transactions
23. IRSPublication 542, Corporations: 21% rate and capital losses
24. California Franchise Tax BoardBusiness tax rates
25. IRSRevenue Procedure 2024-28: allocating unused basis to wallets and accounts (PDF)
26. IRSNotice 2025-7: identifying digital asset units held by a broker (PDF)
27. IRSUnderstanding your Form 1099-DA
28. IRSInstructions for Form 1099-DA (2026): covered securities, basis reporting and exempt recipients
29. IRSAbout Form 1099-DA, Digital Asset Proceeds From Broker Transactions
30. FASBASU 2023-08, Intangibles: Goodwill and Other, Crypto Assets (Subtopic 350-60)