Crypto tax: a checklist for companies

Everything below is drawn from HMRC's Cryptoassets Manual — the official guidance published on GOV.UK setting out how existing tax law applies to cryptoassets. It isn't personalised advice, and it's clear that every case depends on its own facts, but it's a solid starting point for understanding where your company stands.

1. Work out which taxes can apply

A business dealing in exchange tokens — buying and selling them, exchanging them for other assets including other cryptoassets, mining them, or accepting them for goods or services — is likely to be liable for one or more of: Capital Gains Tax, Corporation Tax, Corporation Tax on Chargeable Gains, Income Tax, National Insurance Contributions, Stamp Taxes, or VAT. Which ones apply depends on who's involved and what the business actually does, including whether the activity counts as a trade. Companies report this annually through a company tax return.

2. Convert to sterling, and keep your valuation method consistent

Taxable profits have to be calculated in sterling, even though crypto trades often happen in other currencies or involve swapping one token for another with no sterling value attached. The rules require each transaction to be converted at the rate applicable on the day it took place, with due care taken to reach a fair valuation, applied consistently. A company can elect a non-sterling functional currency instead, converting transactions into that currency and then into sterling at the end of the accounting period.

Profits from crypto trading are generally calculated under Generally Accepted Accounting Practice (UK GAAP, or the equivalent for accounts reported under international standards), subject to any adjustments required or permitted by law. Companies are expected to keep records of the valuation methodology they used.

3. Know when trading in tokens counts as a trade

Whether buying and selling exchange tokens amounts to a financial trade depends on factors including frequency, organisation and intention. This is expected to apply only in exceptional cases, where the activity is highly frequent, organised and sophisticated — the approach is similar to trading in shares and securities, and simply calling the activity a "trade" doesn't make it one for tax purposes.

If the activity is a trade, the profits or losses form part of the company's trading profits rather than being treated as a chargeable gain. If it isn't a trade, other rules — such as chargeable gains or miscellaneous income — may still apply.

4. Mining and staking

The same trade-or-not test applies to mining and staking. A helpful practical example: running a home computer with spare capacity would normally not be a trade, but buying dedicated computers to mine for an expected net profit probably would be.

• If it isn't a trade: the sterling value of the tokens at the time of receipt is generally taxed as miscellaneous income, with appropriate expenses able to reduce the amount chargeable.
• If it is a trade: profits are calculated under the relevant trading tax rules.

Staking is treated as a form of mining, where staking tokens gives an entitlement to newly forged tokens, and it's taxed on the same basis. Either way, if the company keeps the tokens it receives, Corporation Tax on Chargeable Gains may apply later when they're disposed of.

5. Corporation Tax on chargeable gains: what counts as a disposal

Where crypto activity isn't a trade and isn't taxed under the loan relationship or intangible fixed asset rules, any gain on disposal is typically chargeable to Corporation Tax as a chargeable gain. A company is treated as disposing of its tokens when it:

• Sells tokens for money.
• Exchanges them for a different type of token.
• Uses them to pay for goods or services.
• Gives them away to another person — using the tokens' market value at the time of the gift to calculate the gain.

Moving tokens between wallets the company itself beneficially controls isn't a disposal, and neither is a mixer transaction that returns the same type of token. Gifts to charity are generally exempt from tax on the accrued gain, unless the donation is "tainted" or the tokens are sold to the charity for more than their acquisition cost.

6. Pooling for companies

Tokens of the same type that are dealt with generically — without identifying the specific tokens disposed of or acquired — are combined into a single "section 104 pool," with each token type getting its own pool and its own running pooled cost. Two matching rules sit ahead of the pool: a disposal is matched first against tokens acquired the same day, and then against tokens acquired within the previous ten days, on a first-in-first-out basis. Only tokens left over after those two rules go into, or come out of, the pool itself. Companies must still keep records of how much they spent acquiring each type of token.

7. Be ready for the Cryptoasset Reporting Framework (CARF)

CARF is a framework under which reporting cryptoasset service providers (RCASPs) — the exchanges and platforms themselves — must carry out due diligence on their customers and report aggregate transactional data to HMRC each year, from 1 January 2026. Businesses that use these platforms need to supply their provider with certain details; where the business is an entity such as a corporation, the provider also needs due diligence information on the entity's controlling persons. Failing to provide the required information can lead to a penalty, and a provider may refuse further services to the customer until it's supplied.

Getting help

It's worth remembering that each business's tax position turns on its own facts — how it's organised, what it actually does, and how its crypto activity is run. If you'd like help working through your company's wallets, exchanges and accounting records against these rules, we're happy to talk it through.