How is crypto held by a company taxed

Most companies that hold bitcoin, ether or other exchange tokens as an investment are taxed under the chargeable gains rules, not the corporate intangibles regime, because HMRC’s view is that tokens simply held by a company are not intangible fixed assets. Each disposal, including a swap for another token or spending tokens, is a chargeable event, while staking and lending returns are trading income, miscellaneous income or a capital gain depending on the facts.

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Which tax regime applies to a company’s crypto?

HMRC’s Cryptoassets Manual works through the possibilities in order. The answer depends on what the company does with the tokens, not on what they are called.

A trade. If buying and selling tokens amounts to a financial trade, profits and losses form part of trading profits instead of chargeable gains. CRYPTO40150 says HMRC expects this only in exceptional circumstances, judged by frequency, organisation and intention, using the same case law as share dealing.
The intangibles regime. Part 8 of the Corporation Tax Act 2009 takes priority over the chargeable gains rules, but CRYPTO41150 says it applies only if the token is both an intangible asset for accounting purposes and an intangible fixed asset, meaning it was acquired for use on a continuing basis. HMRC states that tokens simply held by the company, even in the course of its activities, do not meet that definition.
Loan relationships. These do not normally apply. CRYPTO41100 explains that exchange tokens are not money and usually have no counterparty, so there is no money debt and no loan relationship.
Chargeable gains. Anything not taxed in one of those ways is the disposal of a capital asset, and CRYPTO41050 says the gain is typically charged to corporation tax as a chargeable gain.

HMRC also does not treat any current cryptoasset as money or currency. CRYPTO41050 lists the consequences: the foreign currency rules in section 328 CTA 2009, the Disregard Regulations and designated currency elections do not apply to tokens.

Why does the accounting treatment not settle the question?

In a company balance sheet crypto is usually shown either as an intangible asset or as stock, as covered in accounting for cryptoassets. Seeing “intangible asset” on the balance sheet tempts people to assume the intangibles regime applies, with amortisation deductible and gains taxed as income. That is the mistake HMRC’s guidance is written to stop. The second test, use on a continuing basis, is what most investment holdings fail. A company that holds tokens for capital growth is holding them, not using them.

CRYPTO41150 also lists exclusions from Part 8 that can apply, including financial assets and assets held for non commercial purposes, and notes that if a company does not prepare accounts that comply with generally accepted accounting practice, the rules apply as if it had.

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What counts as a disposal?

CRYPTO41250 gives the main disposals for a company:

selling tokens for money;
exchanging tokens for a different type of token;
using tokens to pay for goods or services;
giving tokens away, which is valued at market value unless the recipient is a company in the same chargeable gains group.

Moving tokens between wallets the company beneficially controls is not a disposal. Putting tokens into a DeFi platform may or may not be: CRYPTO61620 says it turns on whether beneficial ownership passes, which depends on the platform’s terms. If the recipient can deal with the tokens as it wishes, that points to a disposal at the time of transfer.

How is the gain calculated?

Every transaction must be converted into sterling at the time it happens, using a consistent and recorded method (CRYPTO40100). Allowable costs follow section 38 TCGA 1992. CRYPTO41300 accepts the sterling price paid, transaction fees for recording the transfer on the ledger, and costs of valuation and professional fees. When one token is swapped for another, HMRC accepts splitting the exchange fee 50/50 between the disposal and the acquisition.

Tokens of each type are pooled in their own section 104 pool. CRYPTO41350 sets out two company specific matching rules that take priority over the pool:

disposals are matched first with acquisitions of the same token on the same day;
then with acquisitions in the nine days before the disposal, on a first in, first out basis.

There is no indexation allowance on tokens bought after 2017, because indexation for companies stopped with December 2017.

Illustration only. A company holds 10 tokens bought for a total of £30,000. It later buys 2 more for £10,000, making a pool of 12 tokens costing £40,000. Three weeks later it swaps 6 tokens for a different token worth £36,000 at the time. The cost taken out of the pool is £40,000 x 6/12 = £20,000, so the chargeable gain is £16,000. The new token has a base cost of £36,000, and 6 tokens costing £20,000 remain in the original pool. Had the purchase of 2 tokens been within the nine days before the swap, those 2 would have been matched first.

The gain is added to the company’s profits and taxed at its corporation tax rate. GOV.UK gives the main rate as 25% and the small profits rate as 19%, with marginal relief between £50,000 and £250,000.

How are staking and lending returns taxed?

There is no separate crypto rule for staking income. HMRC’s guidance applies existing principles.

Rewards for validating transactions

CRYPTO40250 treats staking linked to forging new tokens like mining. Whether it is a trade depends on the degree of activity, organisation, risk and commerciality. If it is not a trade, the sterling value of the tokens awarded is generally taxable as miscellaneous income when received, less appropriate expenses. Tokens the company keeps are then subject to corporation tax on chargeable gains when sold.

DeFi lending and liquidity

For DeFi lending and staking, CRYPTO61412 says the return is not interest and, for a company, is not expected to be a loan relationship. Its treatment turns on whether it is revenue or capital:

if the company carries on a trade involving DeFi loans, the profits are trading income under section 35 CTA 2009 (CRYPTO61411);
if there is no trade and the return is revenue in nature, it is charged as miscellaneous income under the sweep up provisions in sections 979 to 981 CTA 2009, measured at the sterling value of the tokens received (CRYPTO61413);
if the return is capital in nature, it is taxed as a chargeable gain.

CRYPTO61214, which CRYPTO61414 applies to companies, lists the pointers. An agreed rate, such as 5% a year, paid periodically by the borrower or platform suggests income. A speculative return realised by disposing of an asset, possibly at a loss, suggests capital. No single factor decides it.

What happens if tokens are lost, stolen or worthless?

Losses on disposals are allowable capital losses, but CRYPTO41400 says they must be reported to HMRC before they can be used. Where tokens become worthless, CRYPTO41450 allows a negligible value claim, made for the whole pool rather than individual tokens. Losing a private key is not itself a disposal, but CRYPTO41500 says a negligible value claim may be possible if there is no prospect of recovering access. Theft is different: CRYPTO41550 says HMRC does not treat it as a disposal, because the owner still has a right to recover the tokens, so no capital loss arises.

What mistakes come up most often?

Claiming amortisation or impairment of crypto as a tax deduction under the intangibles regime when the tokens are simply held.
Ignoring token to token swaps, which are disposals even though no sterling changes hands.
Using the individual capital gains tax matching rules rather than the company rules in CRYPTO41350.
Treating staking rewards as tax free until sold, when they may be income on receipt.
Claiming a loss for stolen tokens, or failing to report losses before using them.
Poor sterling valuation records, which HMRC expects companies to keep.

The individual position is explained in how HMRC taxes cryptoassets and staking and lending rewards. For the wider company computation see capital gains in a company.

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Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 24 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.