Last checked 3 November 2026. Every row below links to the regulator, standard setter, tax authority or statute it comes from. Rules in both countries are changing during 2026 and 2027. If anything here conflicts with the linked source, the source wins, and your own accountant or lawyer decides how it applies to your company.
Most pages on this site take one subject at a time and cover the UK and the US in depth. This page does the opposite: it puts the main rules for a company that holds bitcoin side by side, in five areas, and points to the page that explains each one properly.
At a glance
| Topic | United Kingdom | United States |
|---|---|---|
| Accounting | FRS 102 or FRS 105. No requirements written specifically for cryptoassets, so the treatment is a judgement. FRS 105 allows historical cost only. | US GAAP, ASU 2023-08. Crypto assets in scope at fair value, with changes in net income. |
| Tax | Corporation Tax. Not money or currency. A treasury holding is usually taxed as a chargeable gain on disposal. | Federal income tax. Property, not currency. A C corporation pays 21% federal tax. |
| Reporting | Cryptoasset Reporting Framework. Providers report to HMRC, first reports by 31 May 2027. | Form 1099-DA. Brokers report sales from 2025, many corporations are exempt recipients. |
| Regulation | Providers registered with the FCA for money laundering rules today. A new authorisation regime starts 25 October 2027. | No single regulator. FinCEN, the SEC, the CFTC, bank regulators and the states each have a part. |
| Company types | Sole trader, partnership, LLP or limited company. Only a company or LLP is a separate legal person. | Sole proprietor, LLC, S corporation or C corporation. An LLC is taxed by default by its number of members. |
Accounting: how the holding appears in the accounts
| Topic | United Kingdom | United States |
|---|---|---|
| Framework | FRS 102 for most private companies, FRS 105 for micro entities. The FRC publishes both. | US GAAP, set by the FASB. ASU 2023-08 added Subtopic 350-60 for crypto assets. |
| Measurement | Neither standard has requirements written specifically for cryptoassets. FRS 105 permits historical cost only, so no fair value movements are shown. | Crypto assets in scope are measured at fair value, with changes recognised in net income each reporting period. |
| When it applies | Already in force. Confirm the treatment with your accountant before the first purchase. | Fiscal years beginning after 15 December 2024, including interim periods. Earlier adoption was permitted. |
Source: FRC: FRS 102: The Financial Reporting Standard applicable in the UK and Republic of Ireland, FRC: FRS 105: The Financial Reporting Standard applicable to the Micro-entities Regime, FASB: ASU 2023-08, Intangibles: Goodwill and Other, Crypto Assets (Subtopic 350-60) (PDF).
Go deeperUK accounting: FRS 105 and FRS 102, UK accounting under FRS 102, US accounting under ASU 2023-08, Audit evidence.
Tax: what happens when the company sells or spends
| Topic | United Kingdom | United States |
|---|---|---|
| What bitcoin is for tax | HMRC does not treat cryptoassets as money or currency, so the foreign exchange rules do not apply. | The IRS says digital assets are property, not currency. Notice 2014-21 set this out in 2014. |
| When tax arises | For a company holding bitcoin as an investment, a disposal gives a chargeable gain or loss within Corporation Tax. | A sale or exchange can give a taxable gain or loss, measured against basis, which is generally the cost in US dollars. |
| Matching cost | Bitcoin is pooled, with special rules for coins bought on the same day or within ten days. | Cost basis is tracked by wallet or account. Revenue Procedure 2024-28 explains how to allocate unused basis. |
| Rate | Main rate 25% on profits over £250,000, small profits rate 19% at £50,000 or less, with Marginal Relief in between. | Corporations figure federal tax at 21% of taxable income. State taxes are separate. |
| Records | Each transaction needs a sterling value at the time, using a consistent method that the company records. | The IRS says to keep records of each purchase, receipt, sale, exchange or other disposal, and the dollar value of digital assets received in the business. |
Source: HMRC: CRYPTO41050: Corporation Tax, cryptoassets are not money or currency, HMRC: CRYPTO41200: Corporation Tax on chargeable gains, introduction, HMRC: CRYPTO41350: pooling and the same day and ten day rules, GOV.UK: Corporation Tax rates and allowances, HMRC: CRYPTO40100: Conversion to sterling and accountancy, IRS: Digital assets, IRS: Notice 2014-21: virtual currency is treated as property for federal tax purposes (PDF), IRS: Revenue Procedure 2024-28: allocating unused basis to wallets and accounts (PDF), IRS: Publication 542, Corporations: the 21% rate.
Go deeperCompany tax on bitcoin, Making Tax Digital and bitcoin, QSBS and company bitcoin, Selling or rebalancing.
Reporting: what providers tell the tax authority
| Topic | United Kingdom | United States |
|---|---|---|
| The regime | The Cryptoasset Reporting Framework. UK cryptoasset service providers collect information about their users and transactions and report it to HMRC. | Form 1099-DA, Digital Asset Proceeds From Broker Transactions, filed by brokers. |
| Dates | Reports for 2026 are due between 1 January and 31 May 2027. HMRC says its online reporting service is not live yet. | Gross proceeds for sales from 2025. For sales after 2025, basis is also reported for digital assets that are covered securities. |
| What your company does | Give each UK provider its legal business name, main business address and company registration number. Some entities must also give details of controlling persons. | Many corporations are exempt recipients, so the company may not receive a 1099-DA. It still reports its own gains and losses. |
Source: HMRC: Check if you need to report cryptoasset data to HMRC (Cryptoasset Reporting Framework), HMRC: Information you need to give to UK cryptoasset service providers, IRS: About Form 1099-DA, Digital Asset Proceeds From Broker Transactions, IRS: Instructions for Form 1099-DA: covered securities, basis reporting and exempt recipients.
Go deeperTimeline of rules and products, Bitcoin calendar, Accountant's corner.
Regulation and custody: who supervises the firms you use
A company that buys and holds bitcoin for its own treasury is usually a customer of regulated firms in both countries, not a regulated firm itself. If your company does anything for other people, such as holding bitcoin for clients, take legal advice.
| Topic | United Kingdom | United States |
|---|---|---|
| Today | Cryptoasset businesses must register with the FCA under the Money Laundering Regulations before providing in-scope services in the UK. | Businesses that exchange or administer virtual currency are money transmitters under FinCEN guidance. A user that buys goods or services with it is not. |
| What is changing | The FCA published final rules on 30 June 2026. Firms should apply by 28 February 2027, and the new regime comes into force on 25 October 2027. | The SEC, with guidance from the CFTC, issued an interpretation in March 2026 on how the securities laws apply to types of crypto asset. States license too: New York requires a licence for virtual currency business activity. |
| Checking a custodian | Check the FCA Financial Services Register for what a firm is and is not permitted to do. We have not found a UK defined term that matches the US "qualified custodian". | "Qualified custodian" is defined in the SEC custody rule for investment advisers. An operating company is not bound by it, but it is a useful reference point. |
| Protection if a firm fails | The FSCS says the FCA does not regulate most cryptoassets, so it cannot protect you if a platform that holds them fails. | The FDIC says deposit insurance does not apply to crypto assets. |
Source: FCA: Cryptoassets: AML and CTF regime (registration under the Money Laundering Regulations), FCA: Overview of our cryptoassets regime policy statements (30 June 2026), FCA: FCA opens gateway for regulated crypto (apply by 28 February 2027; regime from 25 October 2027), FCA: Financial Services Register, FSCS: Cryptocurrencies: the risks and your cover, FinCEN: FIN-2013-G001: persons administering, exchanging or using virtual currencies, SEC: Release 33-11412: application of the federal securities laws to certain types of crypto assets (March 2026), Cornell LII: 23 NYCRR 200.3: New York licence requirement for virtual currency business activity, eCFR: 17 CFR 275.206(4)-2: custody rule for investment advisers, definition of qualified custodian, FDIC: Fact sheet: what the public needs to know about FDIC deposit insurance and crypto companies.
In both countries the custody choice is the company's own. The custody guide compares a 2 of 3 multisig, a collaborative multisig, a regulated custodian and an exchange-traded product, and explains why we do not recommend a single-signature wallet for a company treasury.
Go deeperRules and insurance, UK regime from October 2027, Custody options, Custodian due diligence, Multisig for a company, Banking and source of funds.
Company types: who owns the bitcoin and who pays the tax
| Topic | United Kingdom | United States |
|---|---|---|
| Owner runs it alone | Sole trader. You are personally responsible for the business, so the bitcoin is yours and gains are taxed on you. | Sole proprietor, or a single member LLC, which is disregarded for federal tax by default unless it elects to be taxed as a corporation. |
| Two or more owners | Partnership: each partner pays tax on their share. Most LLPs are transparent for tax, so members are taxed on their share of gains. | A domestic LLC with two or more members is taxed as a partnership by default unless it elects otherwise. |
| Separate company | A limited company is legally separate from its owners. It owns the bitcoin and pays Corporation Tax on gains. | A C corporation owns the bitcoin and pays federal tax at 21%. An S corporation passes income, losses, deductions and credits through to shareholders. |
Source: GOV.UK: Set up as a sole trader, GOV.UK: Set up a business partnership, HMRC: PM131450: limited liability partnerships, taxation, GOV.UK: Set up a limited company, IRS: Limited liability company (LLC): default classification, IRS: S corporations, IRS: Publication 542, Corporations: the 21% rate.
Go deeperBitcoin by business type, Directors' duties and bitcoin, Xero and QuickBooks.
What is the same in both countries
- Neither tax authority treats bitcoin as money or currency.
- Tax generally follows a disposal, not a change in price, although US GAAP shows price changes in the accounts.
- Providers now report customer activity to the tax authority, so the company's own records need to match.
- Deposit protection schemes do not cover bitcoin held with a provider.
- The board decides the custody model, and should write down who holds each key and how recovery is tested.
Our judgement, not a rule: a company operating in both countries should brief an adviser in each one. The two systems answer the same questions in different ways, and the differences matter more than the similarities.
Read next
- Accountant's corner: records, year end evidence and exports.
- Board paper outline: how to put the decision to the board.
- Key ceremony walkthrough: set up a 2 of 3 and test recovery.
Sources
Primary sources only. Each link was checked on 3 November 2026. Rules change, so confirm the current version with your adviser.
- FRCFRS 102: The Financial Reporting Standard applicable in the UK and Republic of Ireland
- FRCFRS 105: The Financial Reporting Standard applicable to the Micro-entities Regime
- FASBASU 2023-08, Intangibles: Goodwill and Other, Crypto Assets (Subtopic 350-60) (PDF)
- HMRCCRYPTO41050: Corporation Tax, cryptoassets are not money or currency
- HMRCCRYPTO41200: Corporation Tax on chargeable gains, introduction
- HMRCCRYPTO41350: pooling and the same day and ten day rules
- GOV.UKCorporation Tax rates and allowances
- HMRCCRYPTO40100: Conversion to sterling and accountancy
- IRSDigital assets
- IRSNotice 2014-21: virtual currency is treated as property for federal tax purposes (PDF)
- IRSRevenue Procedure 2024-28: allocating unused basis to wallets and accounts (PDF)
- IRSPublication 542, Corporations: the 21% rate
- HMRCCheck if you need to report cryptoasset data to HMRC (Cryptoasset Reporting Framework)
- HMRCInformation you need to give to UK cryptoasset service providers
- IRSAbout Form 1099-DA, Digital Asset Proceeds From Broker Transactions
- IRSInstructions for Form 1099-DA: covered securities, basis reporting and exempt recipients
- FCACryptoassets: AML and CTF regime (registration under the Money Laundering Regulations)
- FCAOverview of our cryptoassets regime policy statements (30 June 2026)
- FCAFCA opens gateway for regulated crypto (apply by 28 February 2027; regime from 25 October 2027)
- FCAFinancial Services Register
- FSCSCryptocurrencies: the risks and your cover
- FinCENFIN-2013-G001: persons administering, exchanging or using virtual currencies
- SECRelease 33-11412: application of the federal securities laws to certain types of crypto assets (March 2026)
- Cornell LII23 NYCRR 200.3: New York licence requirement for virtual currency business activity
- eCFR17 CFR 275.206(4)-2: custody rule for investment advisers, definition of qualified custodian
- FDICFact sheet: what the public needs to know about FDIC deposit insurance and crypto companies
- GOV.UKSet up as a sole trader
- GOV.UKSet up a business partnership
- HMRCPM131450: limited liability partnerships, taxation
- GOV.UKSet up a limited company
- IRSLimited liability company (LLC): default classification
- IRSS corporations
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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.
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