A Dutch B.V. or Luxembourg company can hold crypto with its own money without a licence. The accounts usually carry it at cost as an intangible or other asset, so gains appear only on sale. Realised gains are taxed at 19% and 25.8% in the Netherlands and 23.87% in Luxembourg City in 2026, with no participation exemption. Luxembourg adds 0.5% net wealth tax on year-end market value. Exchanging crypto is VAT-exempt.
A company can hold bitcoin. The work is in the accounts, the tax return and the bank file
More founders now keep part of their company's surplus cash in bitcoin, ether or stablecoins. In the Netherlands and Luxembourg this is lawful. A Dutch B.V. or a Luxembourg SARL or SA used as a SOPARFI can buy crypto with its own money, keep it and sell it, without any licence.
What changes is everything around the purchase. Accounting standards usually carry it at cost, even when the price has doubled. Tax follows the accounts in both countries, which means gains are mostly taxed when you sell, but Luxembourg also charges net wealth tax on what the company holds at year end. Banks want to know where the money came from when crypto is turned back into euros, and from 2026 the company's exchange reports its transactions to the tax authorities under DAC8.
This note covers a non-financial company holding crypto for itself. If you want to provide crypto services to clients, you need a licence; see our note on the MiCA licence in Luxembourg or the Netherlands. If your question is what your exchange will report about you, see DAC8 crypto reporting.
19% / 25.8%
Corporate tax on realised gains in 2026, step at EUR 200,000.
23.87%
Combined rate in Luxembourg City on realised gains in 2026.
0.5% in Luxembourg
On year-end market value; none in the Netherlands.
Not needed
Investing own funds is not a MiCA service.
How bitcoin shows up in the balance sheet
Not cash, not a financial instrument. Bitcoin is not a deposit or a contractual right to receive cash. All frameworks used in the Benelux therefore put it among intangible assets, or inventory if the company trades crypto as its business.
Dutch GAAP. The Dutch Accounting Standards Board (Raad voor de Jaarverslaggeving) set out its view in RJ-Uiting 2018-7, a discussion paper rather than a binding guideline. Crypto is not a liquid asset or a financial asset. Depending on why it is held, it is an intangible fixed asset, inventory or an 'other investment'. A company holding bitcoin as a reserve or investment usually carries it at acquisition cost, with a write-down when the value falls. Under conditions, Dutch GAAP permits a revaluation to a higher current value, with a revaluation reserve in equity. Our note on Dutch annual accounts covers the filing side.
IFRS. The IFRS Interpretations Committee answered the question in its June 2019 agenda decision on holdings of cryptocurrencies. Crypto held for sale in the ordinary course of business is inventory under IAS 2. Otherwise it is an intangible asset under IAS 38, carried at cost less impairment or, if there is an active market, under the revaluation model. There is no IFRS rule that puts bitcoin at fair value through profit or loss. The IASB has listed crypto-assets as a potential project and is looking at intangible assets held for investment, but as of October 2026 no new standard has been proposed.
Luxembourg GAAP. The Commission des normes comptables has not published a dedicated Q&A on crypto. In practice crypto is an intangible fixed asset or another current asset, at acquisition cost. Fixed assets are written down when a decline in value is expected to be lasting; current assets are carried at the lower of cost and market value. The Lux GAAP fair value option covers financial instruments, which crypto is not. See annual accounts in Luxembourg.
The American contrast. In the United States, ASC 350-60, introduced by ASU 2023-08, has required most crypto-assets to be measured at fair value through net income for fiscal years beginning after 15 December 2024. A Benelux subsidiary of a US group may show bitcoin at cost locally and at fair value in the group accounts.
| Framework | Typical classification | Measurement | Price rise | Price fall |
|---|---|---|---|---|
| Dutch GAAP (RJ) | Intangible fixed asset or other investment | Cost, or current value under conditions | Not in profit; revaluation reserve if chosen | Write-down through profit |
| IFRS | IAS 38 intangible (IAS 2 if traded) | Cost or revaluation model | Other comprehensive income | Impairment through profit |
| Luxembourg GAAP | Intangible fixed asset or other current asset | Acquisition cost | Not recognised | Value adjustment through profit |
| US GAAP | ASC 350-60 crypto-asset | Fair value | Through net income | Through net income |
Stablecoins. An e-money token under MiCA is a claim on the issuer at par, so some auditors treat it closer to a financial asset. Agree the classification before year end.
Law and practice: RJ-Uiting 2018-7 (Raad voor de Jaarverslaggeving, discussion paper on cryptocurrencies); IFRS Interpretations Committee agenda decision 'Holdings of Cryptocurrencies' (June 2019); IAS 2 and IAS 38; IASB agenda paper 17D, May 2026, on intangible assets; Law of 19 December 2002 (Luxembourg accounting), Articles 55 to 64bis; FASB ASU 2023-08 (ASC 350-60).
Dutch B.V.: corporate tax on gains, nothing on paper value
Corporate tax on the gain. For a B.V., crypto is a business asset like any other. Profit is computed under sound business practice (goed koopmansgebruik), and per the KVK guidance a B.V. investing in crypto records it at cost and is taxed on the profit in the year of sale. In 2026, corporate income tax (vennootschapsbelasting) is 19% on the first EUR 200,000 of taxable profit and 25.8% above.
Losses and write-downs. Realised losses reduce taxable profit and can be carried forward without time limit, subject to the cap of EUR 1 million plus 50% of the excess profit per year. Whether an unrealised loss is deductible before sale depends on how the crypto is held. Where it is a current asset, valuation at cost or lower market value is widely applied and accepted under sound business practice. The Belastingdienst has not published a specific position for crypto held as a long-term investment. Pick one method and apply it consistently.
No participation exemption. The participation exemption covers shareholdings of at least 5% in companies. Crypto is not a shareholding, so every euro of gain is in the tax base.
Getting the money out. After corporate tax, a dividend to a Dutch substantial shareholder falls in box 2: in 2026, 24.5% on the first EUR 68,843 per person and 31% above. Dividend withholding tax of 15% is withheld and credited. For non-resident shareholders see dividends to non-residents.
Compare box 3. An individual holding crypto privately is not taxed on gains at all. Box 3 instead taxes a deemed return: in 2026, 6% on investments and other assets above the tax-free EUR 59,357 per person, at 36%, whether the price went up or down. A taxpayer can prove a lower actual return. Inside a B.V. there is no deemed return, but a real gain is taxed twice, once in the company and once on distribution. See the box 3 note.
A Dutch holding B.V. buys 5 BTC in January 2026 at EUR 60,000 each, EUR 300,000 in total, from retained profits. By November the price is EUR 90,000. The B.V. sells 2.5 BTC for EUR 225,000. Cost of the coins sold: EUR 150,000. Realised gain: EUR 75,000. Corporate tax at 19%: EUR 14,250. The remaining 2.5 BTC stay on the balance sheet at EUR 150,000 against a market value of EUR 225,000; the EUR 75,000 unrealised gain is not taxed in 2026. If the B.V. distributes the EUR 60,750 left after tax, the sole shareholder pays box 2 tax of 24.5%, EUR 14,884. For comparison, the same person holding the 5 BTC privately, worth EUR 300,000 on 1 January 2026, would pay box 3 of about EUR 5,198 for 2026: (300,000 − 59,357) × 6% × 36%, and nothing on the sale. Box 3 charges even in a falling year.
Law and practice: Wet op de vennootschapsbelasting 1969, Articles 8, 13 and 22 (rates EUR 200,000 / 19% / 25.8%, Belastingdienst 'Tarieven voor de vennootschapsbelasting'); Wet IB 2001, Article 3.25 (goed koopmansgebruik via Article 8 Wet Vpb) and box 2 and box 3 rates 2026; KVK, 'Zo werkt belasting betalen over crypto's'.
SOPARFI or SARL: income tax on gains, wealth tax on holdings
The circular. Luxembourg has no crypto statute. The direct tax authority's Circular L.I.R. n° 14/5 – 99/3 – 99bis/3 of 26 July 2018 sets the approach. For a fully taxable company, all crypto income is business income. The company may not keep its books in crypto: values are converted into euros at the daily rate of a recognised platform. Gains are taxed when realised, which includes swaps between coins and payments in crypto.
Corporate income tax. A SOPARFI is an ordinary taxable company. Corporate income tax, solidarity surcharge and municipal business tax add up to 23.87% in Luxembourg City in 2026; the CIT rate is lower on taxable income below EUR 200,000. The participation exemption covers qualifying shareholdings, not crypto. Tax follows the commercial balance sheet, so a value adjustment booked under Lux GAAP is in principle deductible, and an unrealised gain is not taxed. Losses can be carried forward for 17 years.
Net wealth tax. This is the cost Dutch companies do not have. Luxembourg companies pay net wealth tax of 0.5% on their unitary value up to EUR 500 million, assessed on 1 January. Under the circular, crypto is valued at fair market value for this purpose, not at book cost. So a SOPARFI with bitcoin bought at EUR 1 million and worth EUR 2 million at year end pays wealth tax on EUR 2 million. The minimum NWT, based on the total balance sheet, is EUR 535 up to EUR 350,000, EUR 1,605 up to EUR 2 million and EUR 4,815 above; the higher of the minimum and the regular charge is due. Exempt participations leave the wealth tax base; crypto does not.
Reducing the NWT. A special reserve of five times the reduction, kept for five years, reduces the net wealth tax. The reduction is limited to the corporate income tax due, so a holding with little taxable income gets little from it.
The SPF question. The SPF pays no income or wealth tax but may hold only financial assets. Whether crypto qualifies was called unclear when the 2018 circular appeared, and the administration has not settled it since. A bitcoin exchange-traded product, which is a transferable security, fits the SPF regime far better. See the SPF note.
A Luxembourg City SOPARFI owned by a founder holds bitcoin bought for EUR 1.2 million, funded by equity. On 31 December 2026 the coins are worth EUR 2 million. Accounts: carried at EUR 1.2 million, no gain recognised. Net wealth tax for 2027: 0.5% × EUR 2,000,000 = EUR 10,000, above the minimum of EUR 1,605 that would apply to a balance sheet of about EUR 1.2 million. If it sold everything at EUR 2 million in 2026, the gain of EUR 800,000 would bear about EUR 190,960 at 23.87%. A sale in 2027 is taxed at the 2027 rate, planned to fall to about 22.80% in Luxembourg City, roughly EUR 182,400. Holding for five years at that value costs about EUR 50,000 of wealth tax before any reduction reserve.
Law and practice: Circular of the Director of Direct Contributions L.I.R. n° 14/5 – 99/3 – 99bis/3 of 26 July 2018 (impotsdirects.public.lu); LIR Articles 18, 23 and 166; Net Wealth Tax Law (VStG) §§ 8 and 8a; Law of 11 May 2007 on the SPF, Article 2; DLA Piper, 'Are your crypto assets taxable in Luxembourg?', November 2025.
Buying, selling and paying suppliers in crypto
Exchange is exempt. In Hedqvist (C-264/14, 22 October 2015) the Court of Justice held that exchanging traditional currency for bitcoin and back is a supply of services exempt from VAT under Article 135(1)(e) of the VAT Directive. Luxembourg's VAT administration adopted this in Circular n° 787 of 11 June 2018, and the Dutch tax authority applies the same rule. Buying and selling bitcoin for the company's own account is not an economic activity at all; it creates no VAT and gives no right to deduct.
Paying a supplier. When a company pays an invoice in crypto, the supply is taxed exactly as if paid in euros, on the euro value of the consideration. The crypto itself is only the means of payment. But handing over crypto is a disposal, so the company realises a gain or loss against its book cost.
The travel rule. Regulation (EU) 2023/1113 has applied to crypto transfers since 30 December 2024. A provider must send the name and wallet details of the originator and beneficiary with every transfer, whatever the amount. For a transfer above EUR 1,000 to or from a self-hosted wallet, the provider must check that the wallet belongs to its customer.
A Luxembourg SARL running a software business pays a Dutch developer's invoice of EUR 10,000 for services in USDC. On the payment date the SARL transfers 10,800 USDC worth EUR 10,000; its book cost for those tokens was EUR 9,700. VAT: the service is supplied to a Luxembourg business, so the SARL self-assesses Luxembourg VAT at 17%, EUR 1,700, under reverse charge and deducts it in the same return, because it has a taxable activity. A pure holding without taxable activity would bear that VAT. Accounting: expense EUR 10,000, USDC derecognised at EUR 9,700, gain EUR 300 taxed with the year's profit.
Law and practice: CJEU, C-264/14 Skatteverket v Hedqvist, 22 October 2015; Council Directive 2006/112/EC, Article 135(1)(e); AED Circular n° 787 of 11 June 2018; Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets, Articles 14 and 16.
Where the coins sit and who sees them
Not a CASP. MiCA defines a crypto-asset service provider as a person providing crypto-asset services to clients on a professional basis. A company buying and holding crypto with its own money provides no service to anyone and needs no authorisation. The line is crossed when it holds or exchanges crypto for others.
| Custody choice | Strengths | Weaknesses | What the auditor asks |
|---|---|---|---|
| Regulated custodian (MiCA CASP) | Segregated assets, insurance options, statements | Fees, onboarding, provider risk | Custody statement at year end |
| Exchange account | Easy trading, low cost | Assets mixed with trading platform risk | Statement plus proof of control |
| Self-custody (hardware, multi-sig) | No counterparty | Key loss, theft, succession, proof of existence | Signed message from the wallet, key procedure |
Since MiCA, custodians must keep client crypto segregated from their own assets, which protects the company if the provider fails. Self-custody needs multi-signature control and a plan for a key holder's departure.
Banks. The hard moment is the return to euros. When the company sends EUR 500,000 from an exchange to its bank, the bank will ask for the purchase trail: the original euro payment to the exchange, statements showing the trades, and the wallet history if coins moved off the platform. Some banks still refuse crypto proceeds outright, so ask before you open the account; see bank accounts for holdings. From 10 July 2027 the EU AML Regulation tightens customer due diligence across the board; see AMLR 2027 for holding companies.
DAC8. Since 1 January 2026, crypto-asset service providers serving EU customers collect tax residence data and report each customer's exchanges and transfers with euro values. Companies are reportable users too. A passive holding company, one with mostly investment income, is also reported with its controlling persons. The 2026 data is exchanged between tax authorities in 2027.
Law and practice: Regulation (EU) 2023/1114 (MiCA), Articles 3(1)(15) and (16), 59 and 75; Council Directive (EU) 2023/2226 (DAC8); Regulation (EU) 2024/1624 (AMLR), applicable from 10 July 2027.
Board approval, dividends in kind and the ETP alternative
Director duties. Buying a volatile asset with company money is a management decision, and directors answer for it. In the Netherlands, Article 2:9 of the Civil Code makes directors liable for serious mismanagement; in Luxembourg, managers are liable for faults in management under the Companies Law of 1915. A loss is not mismanagement in itself; buying without authority or with money needed for creditors can be. Protect the board with an objects clause permitting investments, a written treasury policy and a resolution per significant purchase.
- Limit the share. For example no more than a set percentage of free cash, and never cash needed for tax, wages or debt in the next 12 months.
- Name the assets. Bitcoin only, or a short list; no leverage, lending or staking without a further resolution.
- Fix custody and signatories. Custodian or multi-signature, with two signatories for any transfer.
- Record the price source. One reliable source for year-end values, used every year.
Distributing crypto in kind. A dividend can be paid in bitcoin if the articles allow distributions in kind. In the Netherlands the usual balance sheet and distribution tests apply, valued at market value. For tax, the distributing company is treated as selling the coins at market value, so the latent gain is taxed in the company, and the shareholder receives a dividend equal to that value, subject to withholding tax where applicable.
The ETP alternative. Exchange-traded products backed by bitcoin are listed on European exchanges as debt securities. A company can hold them in an ordinary securities account at its bank. They are financial instruments for accounting and banking purposes, need no key management and fit the SPF more comfortably. The tax on gains in a B.V. or SOPARFI is the same as for coins. The costs are product fees and issuer risk.
Law and practice: Dutch Civil Code, Articles 2:9, 2:216 and 2:248; Luxembourg Law of 10 August 1915 on commercial companies, Article 441-9 and the parallel rules for SARL managers; Wet op de dividendbelasting 1965; LIR Article 164.
Estimate the tax on your crypto position
Enter your position and choose the country. The checker applies 2026 rates to the realised part of the gain, adds the Luxembourg wealth tax on year-end holdings and lists what the bank, auditor and tax office will look at. It assumes an investment held at cost.
Crypto in your company: tax, wealth tax and red flags
Enter what the company paid, what the crypto is worth or sold for, how much was sold this year and what is left at year end. You get the indicative corporate tax on the realised gain at 2026 rates, the Luxembourg net wealth tax on year-end holdings, the accounting treatment and the points a bank or auditor will raise.
Taxed at 19% or 25.8% in the Netherlands and 23.87% in Luxembourg City in 2026.
Luxembourg taxes year-end market value; the Netherlands has no company wealth tax.
Most Benelux accounts carry crypto at cost; only US GAAP uses fair value.
Banks and DAC8 make the purchase history the key document.
Crypto on a company balance sheet: frequent questions
Can a Dutch B.V. or a Luxembourg SARL buy bitcoin with its own money?
Yes. Investing its own funds in crypto needs no MiCA licence, because the company provides no service to clients. Check the objects clause in the articles, adopt a board resolution and expect your bank and auditor to ask questions.
Is an unrealised gain on bitcoin taxed in the company?
Generally not. Dutch corporate tax and Luxembourg corporate income tax follow the realisation principle for crypto held at cost: the gain is taxed when the crypto is sold, exchanged or spent. In Luxembourg, however, the market value at year end is subject to net wealth tax of 0.5%.
Can a Luxembourg SPF hold bitcoin?
The law limits an SPF to financial assets and the tax authorities have not confirmed that crypto qualifies. Commentators consider direct holdings arguable but unclear. An exchange-traded product on bitcoin, which is a security, is the safer route for an SPF.
Must the company report its crypto under DAC8?
The company itself does not report. Its exchange or custodian, as a crypto-asset service provider, reports the company's transactions from 1 January 2026, and for a passive holding company also its controlling persons. The 2026 data is exchanged between tax authorities in 2027.
Can the company pay a dividend in bitcoin?
Yes, a distribution in kind is possible if the articles and the distribution tests allow it. For tax, the company is treated as having sold the crypto at market value, so the latent gain is taxed in the company, and the shareholder is taxed on the market value received.