Bitcoin in business and accounting: IAS 38, treasury and payroll

Holding bitcoins as corporate treasury raises specific accounting and tax questions. The reference IFRS standard (IAS 38) classifies BTC as an intangible asset with indefinite life, which imposes an annual impairment test but no upward revaluation. The US standards (FASB ASU 2023-08) have accepted fair value since 2024, creating an IFRS/US treatment gap to integrate in consolidation×Consolidation (UTXO batching)Merging several small UTXOs into one during a low-fee period, to avoid paying dearly when spending them later. A common wallet management practice.See in the lexicon →.

Three business uses dominate in 2026. MicroStrategy×MicroStrategy (Strategy)US company led by Michael Saylor, which has made bitcoin its main treasury asset since 2020. More than 400,000 BTC accumulated by 2025.See in the lexicon → / Tesla-style corporate treasury : allocation of a share of the treasury in BTC as inflation hedge. Commercial acceptance via BTCPay / OpenNode : customer collection, immediate conversion or partial retention. Bitcoin payroll via Bitwage : salaries paid in BTC, taxed at the EUR rate of the payment day. Each calls for a different accounting and tax treatment.

This article exposes the IAS 38 classification and its impairment test, addresses the IFRS/US divergence and its impact on consolidated groups, compares corporate income tax applied to BTC in France, Germany, Switzerland and Italy, addresses corporate custody×CustodyThe custody of funds. See self-custody and custodial in the dedicated section below.See in the lexicon → (professional multisig×Multisig (multi-signature)Configuration where a transaction must be signed by several independent keys to be valid (for example 2 of 3). Reduces the risk that a single key theft causes loss of funds.See in the lexicon →, Casa Business / Unchained governance), exposes the Bitwage mechanics on the employer side, and lists the pitfalls (volatility, audit, AML×AML (Anti-Money Laundering)Set of rules to fight money laundering. KYC is the first building block. Frames what exchanges can or cannot let you do.See in the lexicon → reporting).

Accounting qualification: IAS 38 intangible assets

The IFRS Interpretations Committee (IFRIC) ruled in June 2019: cryptocurrencies held by a company are intangible assets under IAS 38, unless the company holds them in stock for sale in the ordinary course of business (in which case they are IAS 2 inventories). For an SME like Emilie's holding Bitcoin in treasury without intent to sell in normal activity, IAS 38 applies.

IAS 38 consequences. Four structuring rules. (1) Initial valuation at acquisition cost: 800,000 EUR for Emilie in 2022. (2) Indefinite useful life: no accounting amortisation (unlike software amortised over 3-5 years). (3) Annual impairment test: if recoverable value at 31 December is lower than carried cost, record an impairment. (4) Model choice: cost model (default, French PCG imposes this) or revaluation model (allowed in pure IFRS for assets with an active market, like Bitcoin).

Cost model (French PCG). Balance sheet shows Bitcoin at 800,000 EUR less any impairment. If BTC price falls to 25,000 EUR/BTC, recoverable value 625,000 EUR < cost 800,000 EUR: 175,000 EUR impairment in income statement. If price rises back to 105,000 EUR/BTC: impairment reversal allowed only up to initial cost 800,000 EUR. The 1.8 M EUR latent gain above cost never appears on the balance sheet.

Revaluation model (pure IFRS). Only allowed if Bitcoin has an active market (criterion met since spot ETFs January 2024 and MiCA×MiCA (Markets in Crypto-Assets)European regulation 2023/1114 that frames crypto services across the EU since 2024. Creates the CASP status.See in the lexicon →-authorised CASP×CASP (Crypto-Asset Service Provider)Crypto service provider authorised under MiCA. Must obtain a licence in its home country, valid throughout the EU.See in the lexicon →). In this model, Bitcoin is revalued each year at fair value. Revaluation gains above initial cost go to other comprehensive income (OCI), not to taxable net result. For Emilie under pure IFRS: 2.6 M EUR on balance sheet, 1.8 M EUR in OCI revaluation reserves, no impact on net result. But French SMEs are under PCG, not IFRS, so cost model mandatory for most.

Difference with IAS 2 stock. If Emilie regularly bought and resold BTC in the ordinary course (commercial mining×MiningProcess of validating blocks through proof of work. Consumes electricity by design : that is what secures the network.See in the lexicon →, professional trading), Bitcoin would be IAS 2 stock valued at the lower of cost and net realisable value. This qualification applies to crypto exchanges (Bitcoin Suisse SA, Coinhouse) and commercial miners. For passive treasury, IAS 38 applies.

2024 IFRS position on stablecoins. IFRIC clarified in November 2024: fiat×Fiat (fiat currency)State currency with legal tender status (euro, Swiss franc, dollar), issued by a central bank and not backed by a physical asset. By contrast, Bitcoin has an issuance capped at 21 million units, with no central issuer.See in the lexicon →-backed stablecoins (USDC, EURC) must be analysed case by case. If they confer a right to receive cash from the issuer (Circle), they are IAS 9 financial assets. Otherwise, IAS 38 like Bitcoin. Doctrine stays moving with MiCA application. For pure Bitcoin, no right, so IAS 38 confirmed.

Valuation and annual impairment test

The impairment test is the cornerstone of Bitcoin accounting under IAS 38 cost model. Precise mechanics for Emilie on 2025 financial year.

Step 1: determine recoverable value at 31/12/2025. Bitcoin has an active market (several MiCA×MiCA (Markets in Crypto-Assets)European regulation 2023/1114 that frames crypto services across the EU since 2024. Creates the CASP status.See in the lexicon → CASP×CASP (Crypto-Asset Service Provider)Crypto service provider authorised under MiCA. Must obtain a licence in its home country, valid throughout the EU.See in the lexicon →, several spot ETFs), so fair value is observable. December 2025 average price published by CoinMarketCap: 93,000 EUR/BTC. For Emilie's 25 BTC: 25 × 93,000 = 2.325 M EUR. This is the recoverable value.

Step 2: compare to carried cost. Initial cost: 800,000 EUR. Recoverable value 2.325 M EUR > cost. No impairment to record. Balance sheet stays at 800,000 EUR (cost model). If Emilie was under pure IFRS with revaluation model, balance sheet would go to 2.325 M EUR with 1.525 M EUR of OCI reserves.

Step 3: test impairment indicators during the year. IAS 36 imposes immediate impairment test if an adverse event occurs: major price drop (> 25 %), custody×CustodyThe custody of funds. See self-custody and custodial in the dedicated section below.See in the lexicon → platform bankruptcy, loss of access to private keys. For Emilie: no triggering event on 2025, annual test suffices.

Worked example: bearish scenario. Suppose end of 2026 BTC price drops to 35,000 EUR/BTC. Recoverable value 25 × 35,000 = 875,000 EUR > cost 800,000 EUR. Still no impairment. If price drops to 28,000 EUR/BTC: 25 × 28,000 = 700,000 EUR < cost. 100,000 EUR impairment to record in 2026 result, reducing taxable net result by 100,000 EUR. Associated corporate tax saving: 25,000 EUR. Balance sheet now shows Bitcoin at 700,000 EUR. If price rises back to 50,000 EUR/BTC in 2027: recoverable value 1.25 M EUR, but impairment reversal capped at 800,000 EUR (initial cost). 100,000 EUR reversal in 2027 result.

Steering consequences. Bitcoin volatility partially transmits to accounting result via impairments and reversals. For an SME, this can create an undesirable accordion effect. Steering solutions: (a) accept accounting volatility as reflection of treasury strategy, (b) limit Bitcoin share to a controlled percentage of treasury (Emilie: 800k out of 2.1M or 38 %, at the high end of observed practice), (c) communicate transparently to shareholders and auditors.

Corporate tax treatment on disposal gains

Bitcoin disposal gain realised by a company enters taxable result at normal corporate tax rate, with no specific favourable regime. Detail by reference jurisdiction.

France: 25 % corporate tax (2026 normal rate). Emilie selling 5 BTC at 105,000 EUR (price 525,000 EUR, cost 160,000 EUR) generates a 365,000 EUR gain. This gain adds to the financial year's taxable result. Tax owed: 365,000 × 25 % = 91,250 EUR. If the company is at 15 % reduced rate (SME up to 42,500 EUR profit), the excess fraction taxes at 25 %. No long-term abatement (article 219 CGI regime does not apply to crypto-assets).

Germany: Körperschaftsteuer 15 % + Gewerbesteuer ~14 %, total ~29-32 %. Corporate gain not concerned by §23 EStGק23 EStG (Spekulationsfrist)German tax provision that fully exempts Bitcoin capital gains after a holding period of more than 12 months.See in the lexicon → exemption (reserved for individuals). Same calculation: 365,000 EUR gain × 29 % = 105,850 EUR of tax. Plus Soli 5.5 % on KSt if applicable. More unfavourable than France for a German company holding Bitcoin in treasury, explaining why corporate lever is less used in DE than in FR or IT.

Switzerland: cantonal corporate profit tax ~12-21 %. Less unfavourable. In Geneva ~14 %, in Zug ~12 %, in Vaud ~14 %. Gain 365,000 EUR × 14 % = ~51,100 EUR. Almost half of France. The Swiss company holding BTC is taxed as company, unlike the exempt individual. Practical consequence: for a wealthy Swiss, keeping Bitcoin as individual stays fiscally superior to going through a Swiss AG.

Italy: IRES 24 % + IRAP 3.9 %, total 27.9 %. Gain 365,000 EUR × 27.9 % = ~101,835 EUR. Level comparable to Germany. Note: no 2,000 EUR allowance at corporate level (allowance reserved for individuals under cripto-attività×Cripto-attivitàItalian legal term (law 197/2022) for crypto assets, taxed at a 26 percent flat rate above an annual threshold of 2,000 EUR.See in the lexicon → regime).

Corporate tax loss offset. In case of BTC disposal at loss (price dropped below acquisition cost), the loss is deductible without cap from taxable result. Carry-forward over 10 years in France (article 209 I CGI), 5 years in Italy, unlimited in Germany and Switzerland. For Emilie hypothetically with a 200,000 EUR loss in 2027 (price drop), immediate 50,000 EUR corporate tax saving on 2027 result, or carry-forward if fiscal loss.

Bitcoin VAT: 2015 CJEU exemption. CJEU ruling C-264/14 Skatteverket vs Hedqvist (October 2015) ruled: Bitcoin purchase-sale operations against fiat×Fiat (fiat currency)State currency with legal tender status (euro, Swiss franc, dollar), issued by a central bank and not backed by a physical asset. By contrast, Bitcoin has an issuance capped at 21 million units, with no central issuer.See in the lexicon → are VAT-exempt throughout EU (assimilation to exchange×ExchangeService that lets you buy, sell and swap cryptocurrencies against fiat money. Examples : Kraken, Coinbase, Bitstamp, Bitvavo. Most are custodial.See in the lexicon → operations). Confirmed in France by BOI-TVA-CHAMP-30-10-30. No VAT to invoice on BTC sale by Emilie. On associated fees (platform commissions), VAT remains due according to usual regime.

Central table: 5 accounting scenarios by jurisdiction

The table below condenses the accounting and tax treatment of five common Bitcoin scenarios in business across the 4 jurisdictions. Assumptions: company under local framework (PCG France, HGB Germany, Codice Civile Italy, CO Switzerland), not pure IFRS. Price 105,000 EUR/BTC for valuations.

Comments. Scenario 1 shows the homogeneous qualification in Europe: intangible asset (PCG, CC, IAS 38) or Anlagevermögen (HGB), with a Swiss nuance where the CO allows classification as current asset if intended to be realised within the year. Scenario 2 highlights the rigidity of cost model: despite higher recoverable value (2.325 M EUR for 25 BTC at 93k), balance sheet stays at 800k EUR everywhere except in pure IFRS with revaluation.

Scenario 3 is central: corporate tax varies from 14 % (Switzerland) to 29 % (Germany), a 55k EUR gap for the same 365k EUR gain. This is a Bitcoin treasury location factor for international groups. Scenario 4 illustrates accounting asymmetry: we impair immediately downward but never revalue upward beyond initial cost. Net effect: balance sheet systematically underestimates BTC real value as long as price rises.

Scenario 5 confirms VAT exemption. Practical for exchanges and companies regularly trading: no collected VAT to invoice clients on BTC sale, but no deductible VAT either on fees associated to this exempt activity (according to general pro rata deduction rule).

Consolidated Emilie case. At 31/12/2025, her balance sheet shows Bitcoin at 800,000 EUR. Annex note: « Crypto-assets held in treasury, fair value at 31/12 of 2.325 M EUR (December average price 93k EUR/BTC), valuation at cost in accordance with PCG art. 619-1, latent gain not recognised 1.525 M EUR ». This annex mention is mandatory in France for significant assets under IAS 1, and provides information to shareholders and auditors without distorting the result. Deloitte auditor verifies effective BTC possession (public consultation of BTC addresses associated to Emilie's 2-of-3 multisig×Multisig (multi-signature)Configuration where a transaction must be signed by several independent keys to be valid (for example 2 of 3). Reduces the risk that a single key theft causes loss of funds.See in the lexicon →), correct application of impairment test, and supporting document consistency.

Bitcoin payroll via Bitwage and social compliance

A few European companies offer voluntary employees a partial salary conversion option to Bitcoin. Bitwage (bitwage.com), based in San Francisco but operating in EU, is the reference service. It interposes between employer and employee: the employer pays EUR salary to Bitwage, which converts to BTC at the day's price and transfers to the employee's wallet×WalletSoftware or device that manages your Bitcoin keys and lets you sign transactions. A wallet does not really « hold » your bitcoins, it holds the keys that prove you own them.See in the lexicon →.

Legal salary framework. In the 4 jurisdictions, salary must be denominated and paid in legal currency (EUR or CHF). Article L. 3241-1 of French Labour Code, §107 GewO German, articolo 2099 Italian Codice Civile, article 322 Swiss CO. BTC conversion is legally allowed at the employee's request on a fraction of net salary (after social and tax deductions calculated on EUR gross).

Bitwage mechanics. (1) Employer pays net salary in EUR on a Bitwage account. (2) Bitwage takes 1-1.5 % commission and converts to BTC at spot price. (3) BTCs are transferred to the employee's receiving address (self-custody×Self-custodyModel in which you hold your own private keys. Your bitcoins depend on no third party. This is Bitcoin's founding promise.See in the lexicon → wallet or CASP×CASP (Crypto-Asset Service Provider)Crypto service provider authorised under MiCA. Must obtain a licence in its home country, valid throughout the EU.See in the lexicon → platform). (4) Payslip stays in EUR gross, with mention of EUR net, with a note specifying BTC conversion performed. (5) Social and tax contributions are calculated normally on EUR gross.

Fiscal consequences for the employee. Taxable income stays the EUR gross amount. No additional taxation on day's EUR-BTC conversion. However, the holding duration of received BTC starts that day for threshold regimes (12 months Germany §23 EStGק23 EStG (Spekulationsfrist)German tax provision that fully exempts Bitcoin capital gains after a holding period of more than 12 months.See in the lexicon →, for example). Tax acquisition cost of BTC: EUR value on receipt day. If the employee later sells the BTC, gain calculated against this value.

For Emilie in France. If she offers Bitwage to her 40 employees in 2026, about 5-10 % will be interested (rate observed at Galaxus, Strike, Bitcoin Standard Companies). For each employee opting for 10 % salary in BTC: on 3,500 EUR net monthly, 350 EUR converted to ~0.003 BTC per month. No additional charge for Emilie (Bitwage commission paid by employee on his fraction). Internal communication and HR policy to formalise.

Audit, custody and cybersecurity

Holding Bitcoin in corporate treasury imposes three specific arrangements compared to traditional EUR treasury.

Reinforced annual audit. The auditor must verify×Don't trust, verifyBitcoiner mantra. Trust no one (bank, government, exchange, influencer), verify on your own through your own node.See in the lexicon → (a) effective possession of BTC declared on balance sheet, by signature demonstration with private keys on an auditor's message (« proof of reserves » technique), (b) correct application of impairment test in case of price drop, (c) accounting traceability between acquisition, valuation, disposal and result. For IFRS companies, additional annex note requirements on fair value and risk management policy. Additional audit cost: typically 5-15k EUR/year for an SME like Emilie's according to complexity.

Custody×CustodyThe custody of funds. See self-custody and custodial in the dedicated section below.See in the lexicon →: multisig×Multisig (multi-signature)Configuration where a transaction must be signed by several independent keys to be valid (for example 2 of 3). Reduces the risk that a single key theft causes loss of funds.See in the lexicon → self-custody×Self-custodyModel in which you hold your own private keys. Your bitcoins depend on no third party. This is Bitcoin's founding promise.See in the lexicon → recommended. Three options in increasing risk order. (1) N-of-M multisig self-custody with hardware wallets (Coldcard×Ledger, Trezor, Coldcard, BitBoxMain hardware wallet brands. Ledger Nano S Plus / X (French, the best-seller), Trezor Model T (Czech, open source), Coldcard Mk4 (Canadian, ultra-secure, Bitcoin-only), BitBox02 (Swiss, open source).See in the lexicon → Q, BitBox02, Trezor×Ledger, Trezor, Coldcard, BitBoxMain hardware wallet brands. Ledger Nano S Plus / X (French, the best-seller), Trezor Model T (Czech, open source), Coldcard Mk4 (Canadian, ultra-secure, Bitcoin-only), BitBox02 (Swiss, open source).See in the lexicon → Safe 5) distributed among several directors. For Emilie: 2-of-3 between Emilie + Marc-Antoine + a fiduciary third party (patrimonial lawyer). No single loss in case of failure or compromise. No third-party risk (platform bankruptcy, administrative freeze). (2) Authorised institutional custody at a MiCA×MiCA (Markets in Crypto-Assets)European regulation 2023/1114 that frames crypto services across the EU since 2024. Creates the CASP status.See in the lexicon → CASP×CASP (Crypto-Asset Service Provider)Crypto service provider authorised under MiCA. Must obtain a licence in its home country, valid throughout the EU.See in the lexicon → (Coinhouse Custody, Bitcoin Suisse SA, Sygnum). Cost: 0.5-1 % annual on custody value. Advantage: insurance against theft/technical loss. Drawback: counterparty risk in case of bankruptcy (cf. FTX×FTXCentralised exchange that collapsed spectacularly in November 2022. Sam Bankman-Fried was convicted. Dragged Blockfolio and many funds down with it.See in the lexicon → 2022). (3) Trading platform (Coinbase Custody, Kraken). To avoid for corporate treasury: no systematic separation of client funds, hacking history and bad governance.

Specific cybersecurity. Four major risks. (a) Targeted phishing×PhishingAttack where someone impersonates a legitimate service via email, SMS or clone website, in order to extract your credentials or your seed phrase.See in the lexicon → on directors to exfiltrate seed phrases: training, dual-control on any operation, mandatory offline signature. (b) Physical attack (hardware wallet×Hardware walletSmall dedicated device (Ledger, Trezor, Coldcard, BitBox, etc.) that keeps the private key away from a potentially compromised computer. Signs transactions inside the device itself.See in the lexicon → theft): multisig prevents drainage by single compromised wallet×WalletSoftware or device that manages your Bitcoin keys and lets you sign transactions. A wallet does not really « hold » your bitcoins, it holds the keys that prove you own them.See in the lexicon →. (c) Internal compromise by malicious director: multisig with independent third party adds external counter-signature. (d) Access loss (death, departure, seed forgetting): backup shared among signatories, documented recovery procedure, annually tested.