Crypto Tax for Companies UK | Corporation Tax

Two business professionals reviewing figures on a laptop in an office — Corporate crypto is not personal crypto with a company name on it.

The order of analysis

For a company, the first question is never “what rate?” — it is which regime applies, and HMRC works through them in a fixed order: loan relationships, then intangible fixed assets, then trading profits, then chargeable gains.

The intangible fixed assets regime under Part 8 CTA 2009 catches exchange tokens only where both conditions are met: the tokens are an intangible asset for accounting purposes, and they meet the definition of an intangible fixed asset — created or acquired for use on a continuing basis. HMRC is explicit that tokens merely held by a company, “even when held in the course of its activities”, do not qualify (CRYPTO41150).

The practical result is that most corporate crypto holdings fall outside the intangibles regime and into chargeable gains — taxed as corporation tax on chargeable gains, with corporate pooling, allowable costs and losses following the equivalent rules to the personal ones.

Most corporate crypto holdings fall outside the intangibles regime and into chargeable gains.

The main corporate situations

Situation	Treatment
Company holds crypto on the balance sheet as treasury	Usually chargeable gains. Disposals, including token-to-token swaps, produce chargeable gains or allowable losses within the corporation tax computation.
Company accepts crypto as payment for goods or services	Trading receipt. HMRC: where tokens are held as part of an existing trade, profits of a revenue nature are included in trading profits. Value in sterling at the point of the transaction.
Company trades crypto as its business	Only in exceptional circumstances would HMRC accept that buying and selling tokens amounts to a financial trade in itself. Where it does, profits are trading profits, not chargeable gains.
Company mines or runs validators	Ordinarily a trade at any commercial scale, with equipment capital allowances and deductible power costs, and the mined tokens taking a trading-stock base cost on appropriation.
Company uses DeFi	The same beneficial-ownership disposal analysis applies — and note that the no gain, no loss measure taking effect on 6 April 2027 is stated to affect individuals and trustees. The policy paper does not address companies, so corporates should not assume it applies to them.
Company pays staff or contractors in tokens	See below — the most commonly mishandled area in corporate crypto.

A Bitcoin coin beside a laptop, representing crypto held on a company balance sheet — A company holding rather than converting is running an unhedged position that belongs in the accounts.

Paying people in crypto: assume PAYE applies

Paying employees in cryptoassets is earnings — money’s worth — and is subject to Income Tax and National Insurance (CRYPTO42050). The critical question is whether the tokens are readily convertible assets. HMRC’s stated position is blunt: “HMRC considers that exchange tokens generally will be readily convertible assets” (CRYPTO42100).

Where they are, the employer must value the asset using its best estimate, operate PAYE and Class 1 NIC, and report in real time. If the employer cannot recover the tax from other payments, the employer still owes HMRC. And the employee must make good the Income Tax and employee Class 1 NIC within 90 days of the end of the tax year, or suffer a further charge on both. Where the tokens are genuinely not readily convertible, there is no PAYE, but the employer reports a benefit in kind and pays Class 1A NIC, and the employee declares the amount on the employment pages of their return.

Offshore token-compensation arrangements also need to be tested against the employment income provided through third parties rules — the disguised remuneration code — before anyone signs anything.

VAT

Selling goods or services for crypto: VAT is due as normal, on the sterling value of the tokens at the point the transaction takes place. No VAT is due on the supply of the token itself.
The supply of services required to exchange exchange tokens for legal tender is VAT exempt under Item 1, Group 5, Schedule 9 VATA 1994, following the CJEU decision in Skatteverket v Hedqvist (C-264/14) and HMRC’s position since 2014.
Mining is outside the scope of VAT — HMRC does not regard it as an economic activity for VAT purposes.
Be careful here. HMRC has not restated the crypto VAT position since Brexit, Hedqvist is assimilated EU case law, and HMRC has published nothing on the VAT treatment of NFTs or DeFi services. This is an area to take a documented position on rather than assume.

Glass-fronted commercial office building, representing UK limited companies holding cryptoassets — Assume readily convertible asset treatment, PAYE and Class 1 NIC until advised otherwise.

What we do for crypto businesses

Statutory accounts and corporation tax returns for companies holding, accepting, mining or trading cryptoassets
Regime analysis — loan relationships, intangibles, trading or chargeable gains — documented, so it survives an enquiry
Crypto treasury policy, valuation methodology and month-end reconciliation into the nominal ledger
Payroll for token compensation, including RTI, Class 1 and Class 1A, and the 90-day make-good position
VAT reviews for businesses accepting crypto or operating in Web3
R&D tax relief claims for genuine protocol and infrastructure development
Company formation, structuring and international expansion for Web3 businesses

Frequently asked questions

Should I hold my crypto personally or through a company?

There is no default answer. It turns on what you intend to do with the proceeds, your other income, whether the activity is investment or trade, and your exit horizon. A company pays corporation tax on gains and then you face a further charge on extraction; an individual pays 18% or 24% with a £3,000 annual exemption. Model it before you move anything — transferring appreciated crypto into a company is itself a disposal at market value.

Does my company get the 2027 no gain, no loss DeFi relief?

Do not assume so. The Budget 2025 policy paper states the measure affects individuals and trustees, and does not address companies. Unless and until that changes, corporates should plan on the current analysis — which makes the beneficial-ownership question materially more important for companies than for individuals from April 2027 onwards.

We accept crypto payments. When do we recognise the income?

At the point of the transaction, in sterling. Any subsequent movement in the value of the tokens you retain is a separate matter, taxed when you dispose of them. Businesses that hold rather than immediately convert are running an unhedged position that needs to be visible in the accounts.

Can we pay contractors in stablecoins?

Commercially yes; the tax analysis is the issue rather than the mechanism. For employees, assume readily convertible asset treatment and PAYE unless advised otherwise. For genuine contractors, the usual employment-status analysis applies first — paying in tokens does not change whether someone is an employee.

This page is general guidance on UK tax law as at 9 August 2026 and is not advice for any particular person or situation. Tax treatment depends on your individual circumstances and may change. Where we quote HMRC’s internal manuals, note that those manuals are guidance prepared for HMRC staff, are not law, and do not bind HMRC in an individual case. Please take advice before acting. Reviewed by the TaxDigit crypto tax team · Last reviewed 9 August 2026. Updated August 2026.

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TaxDigit is a UK cryptocurrency accountant practice for companies. Chartered certified accountants advising Web3 businesses, treasury holders and companies accepting crypto as payment.

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