Bitcoin for UK Businesses: Tax and Treasury Sources

Contents of the manual's business section, covering trading, mining, staking, Corporation Tax, Income Tax, VAT, stamp duties and the Cryptoasset Reporting Framework.

Explains which taxes can apply to a business that buys, sells or accepts exchange tokens, and that the answer depends on the business's structure and activities.

Explains that taxable profits from cryptoassets are calculated in sterling, how an exchange rate is set where a transaction has no sterling value, and that trading profits generally follow accepted accounting practice.

Explains how HMRC's view of whether buying and selling exchange tokens amounts to a financial trade depends on frequency, organisation and intention, and the resulting Income Tax or company profit treatment.

Explains how mining rewards are taxed for businesses and companies, contrasting casual mining with dedicated equipment bought for profit, and covering miscellaneous income, trading profits and later chargeable gains.

Explains HMRC's view of staking by businesses, covering when it amounts to a trade, when awards are taxed as miscellaneous income, and later Capital Gains Tax or Corporation Tax on chargeable gains.

Explains that businesses accepting or paying exchange tokens in the course of a trade must include the revenue profits in taxable trading profits for Income Tax or Corporation Tax.

Contents of the manual's Corporation Tax guidance, covering loan relationships, intangible fixed assets, chargeable gains, pooling, losses, lost private keys, fraud, forks and airdrops.

Introduces Corporation Tax on exchange tokens held by companies, including HMRC's view that cryptoassets are not currency, so foreign currency rules do not apply, and when chargeable gains arise.

Sets out HMRC's view that exchange tokens are not money and create no loan relationship for companies, while an ordinary money loan secured on tokens does.

Describes when companies accounting for exchange tokens as intangible assets fall under the Corporation Tax intangible fixed assets rules, and why tokens simply held by a company generally do not qualify.

Sets out who is liable to Corporation Tax or Capital Gains Tax on gains from exchange tokens held as an investment, and why tokens count as chargeable assets.

Describes what counts as a disposal of exchange tokens for Corporation Tax on chargeable gains, including swaps, gifts and wallet transfers, mixer use, and disposals to charity.

Describes HMRC's view that swapping tokens across ledgers may be a disposal depending on the facts, and that one-way transfers such as ether to the Beacon Chain fall under section 43 TCGA.

Lists the costs HMRC treats as allowable under section 38 TCGA 1992 when calculating token gains, including how exchange fees, token swaps and mining costs are treated.

Explains how section 104 pooling applies to exchange tokens held by companies, with separate pools per token type, and the same-day and nine-day exceptions, illustrated by worked examples.

Covers how a company's losses on disposing of exchange tokens are treated as allowable losses that must be reported to HMRC, and notes special rules for disposals to connected persons.

Explains how a company can make a negligible value claim for exchange tokens that have become worthless, covering the whole-pool requirement, what the claim must state and reporting the loss.

Explains HMRC's view that misplacing a private key is not a disposal for Capital Gains Tax, and that a negligible value claim may be made if recovery has no prospect.

Sets out HMRC's view that theft is not a disposal, so victims cannot claim a Capital Gains Tax or Corporation Tax loss, and when negligible value claims may apply to worthless tokens.

Explains how soft and hard forks work and HMRC's treatment of new tokens from a hard fork, including section 104 pool splitting, cost apportionment and negligible value claims.

Describes how airdropped tokens are treated for Corporation Tax on chargeable gains, including pool allocation and why section 43 TCGA does not apply where value is not derived from existing holdings.

Describes HMRC's view that exchange tokens given to employees are money's worth, so count as employment income subject to Income Tax and National Insurance contributions on their value.

Explains HMRC's view that exchange tokens generally are readily convertible assets, and how employers account for PAYE and Class 1 National Insurance when paying employees in them.

Explains HMRC's view that cryptoassets provided as readily convertible assets count as earnings for Class 1 National Insurance, which the employer accounts for through PAYE.

Covers PAYE and National Insurance where an employee is paid in exchange tokens that are not readily convertible assets, including Self Assessment declaration and employer Class 1A treatment as a benefit.

Covers the Income Tax and PAYE position where exchange tokens are provided to an employee by a third party under Part 7A ITEPA 2003, including the National Insurance consequences.

Describes HMRC's view that exchange tokens are not currency or money, so do not qualify for employer contribution deductions to registered pension schemes, and the consequence if they are transferred in.

Describes Stamp Duty on instruments transferring stocks or marketable securities and Stamp Duty Reserve Tax on agreements to transfer chargeable securities, pointing to the Stamp Taxes on Shares Manual.

Sets out HMRC's view on whether transfers of exchange tokens fall within Stamp Duty or Stamp Duty Reserve Tax, which depends on whether they are stock, marketable securities or chargeable securities.

Explains how exchange tokens given as consideration are treated for Stamp Duty and Stamp Duty Reserve Tax, including HMRC's view that they are not money and the role of debt.

Outlines that Stamp Duty Land Tax applies to land and buildings in England and Northern Ireland, with Land and Buildings Transaction Tax in Scotland and Land Transaction Tax in Wales instead.

States HMRC's view that transfers of exchange tokens are not land transactions, so Stamp Duty Land Tax is not payable on them.

Explains that exchange tokens given as consideration for a land transaction count as money or money's worth and so are chargeable to Stamp Duty Land Tax, valued at market value.

Sets out the VAT treatment of cryptoasset exchange tokens, covering sales of goods for tokens, mining receipts, exchange services and the Hedqvist ruling, with HMRC treating some positions as provisional.

Covers HMRC's approach to cryptoasset and distributed ledger companies seeking EIS or SEIS status, which activities do or may not meet qualifying trade conditions, and advance assurance.

Covers HMRC's treatment of cryptoassets used in betting or gaming as equivalent to cash for excise duty purposes, with valuation provisions in section 191 of the Finance Act 2014.

Sets out how Digital Services Tax applies to cryptoasset exchanges as online marketplaces, and HMRC's reasons why they are unlikely to qualify for the online financial marketplace exemption.

Describes the Cryptoasset Reporting Framework, under which UK reporting cryptoasset service providers must carry out due diligence and report customer transaction data to HMRC annually from 1 January 2026.

Introduces the Corporation Tax treatment of returns from DeFi loans, covering when a company's activity is a trade, and when a return is a chargeable gain or miscellaneous income.

Explains how the return on a DeFi loan or stake is taxed for Corporation Tax, covering capital and revenue receipts, the miscellaneous income provisions and HMRC's view that no loan relationship arises.

Sets out how a company's return on a DeFi loan or liquidity provision is charged to Corporation Tax as miscellaneous income at sterling value, with principal repayment treated as capital.

States that the capital or revenue nature of a DeFi lending return is judged for Corporation Tax on the same considerations as for Income Tax, cross-referring to the Income Tax page.