The Bitcoin WorldA division of Global Digital Treasury

Accounting for Bitcoin transaction costs and network fees

By Muhammad Bana5 min readAccounting & Tax
Key takeaways
  • Bitcoin transaction costs include visible items such as commissions and network fees, and less visible ones such as the spread built into the price
  • Under both frameworks, fair value excludes transaction costs, so any costs capitalised on purchase pass through profit at the first remeasurement or impairment
  • Network and custody fees paid in Bitcoin are small disposals, so they need a policy for measurement, presentation and tax

Bitcoin transaction costs cover every cost of acquiring, moving, holding and selling Bitcoin: commissions, spreads, venue fees, network fees and custody fees. Each needs an accounting treatment, and the treatment depends on the type of cost and the framework. A common thread runs through both US GAAP and IFRS: fair value excludes transaction costs, so any cost added to the carrying amount on purchase does not survive the next fair value measurement.

This article sets out the main cost types and how each is commonly treated. Practice varies, and in several areas the standards leave room for judgement. Companies should agree their policies with their auditors and take their own accounting and tax advice.

The cost types finance teams will see

Bitcoin costs fall into five groups.

  • Explicit trading costs. Commissions or fees charged by an OTC desk, broker or venue on a buy or sell, shown separately on the confirmation.
  • Implicit trading costs. The spread or mark-up built into the quoted price. An all-in OTC price often includes the provider's margin without showing it as a fee.
  • Funding costs. Bank transfer charges and foreign exchange costs incurred to move cash to the counterparty.
  • Network fees. Fees paid to miners to include a transaction in a block, incurred when Bitcoin moves on-chain. They are usually paid in Bitcoin. See how Bitcoin network fees work.
  • Holding costs. Custody fees, usually charged periodically as a percentage of assets held, paid in cash or in Bitcoin.

The accounting differs for each, so the first control is simply to capture them separately. An execution report that itemises the price, fees and timestamps makes this possible. See what a Bitcoin execution report should contain.

Bitcoin transaction costs at a glance

Cost type US GAAP (ASU 2023-08) common practice IFRS (IAS 38 cost model) common practice
Purchase commission Often included in initial cost; absorbed at first remeasurement. Some companies expense immediately Included in cost as directly attributable
Spread in the price Part of the price paid; not recorded separately Part of the price paid; not recorded separately
Selling commission Reduces proceeds; affects gain or loss on disposal Reduces net disposal proceeds; affects gain or loss
Network fee on own transfer Expense; Bitcoin used is derecognised Expense; Bitcoin used is derecognised
Custody fee Period expense Period expense

The table describes common approaches, not mandatory ones. Where a choice exists, it should be documented in the accounting policy and applied consistently.

Acquisition costs and the first remeasurement

US GAAP

The FASB standard on digital assets (ASU 2023-08) changed how Bitcoin is measured after purchase, but it did not add specific guidance on initial measurement. Under existing guidance for acquiring individual assets, many companies include directly attributable costs, such as commissions, in the initial cost. Investment companies applying their own industry guidance generally expense them.

In practice, the choice mainly affects presentation. Fair value under ASC 820 excludes transaction costs. So at the first remeasurement, a capitalised commission becomes part of the remeasurement gain or loss. A company that expenses it instead records it as a fee. The effect on net income for the period is the same, but the line items differ. Cost basis for disclosure purposes will also include or exclude the commission depending on the policy. See measuring Bitcoin fair value.

IFRS

Under IAS 38, the cost of a separately acquired intangible asset includes its purchase price and directly attributable costs. Commissions are therefore normally capitalised. Under the cost model they stay in the carrying amount until disposal or impairment. Under the revaluation model, the first revaluation to fair value excludes them, so they are absorbed in that first revaluation.

Network fees

Network fees are the cost type most specific to Bitcoin.

When a company moves Bitcoin between its own accounts, for example from a trading account to cold storage, it pays a fee in Bitcoin. The company has used part of its Bitcoin to pay for a service. In accounting terms, that is a small disposal:

  • The fee is recognised as an expense, usually measured at the fair value of the Bitcoin given up.
  • The Bitcoin used is derecognised at its carrying amount.
  • Any difference is a small gain or loss on the Bitcoin.

Two judgements arise. First, whether a network fee paid to move newly purchased Bitcoin into custody is a directly attributable acquisition cost or a separate expense. Second, whether a simplified method can be used for small fees. Both should be settled in policy, with a materiality threshold agreed with the auditor. The journal entries article includes a worked network fee example.

CFO tip: ask every execution and custody provider to state, in writing, which fees are deducted in Bitcoin and which are invoiced in cash. Fees deducted in Bitcoin quietly reduce units held, and they are the most common cause of small reconciliation breaks.

Spreads, custody fees and presentation

Spreads and best execution

The spread is the largest trading cost for many companies, and it never appears as a separate line in the accounts. It is embedded in the price, so it is embedded in cost.

That does not make it invisible to management. Comparing execution prices against an independent reference at the time of the trade shows the implicit cost. This belongs in treasury reporting and best execution reviews, not in the general ledger. See best execution for corporate Bitcoin trades.

Custody fees and presentation

Custody fees are a cost of holding, not acquiring, and are expensed as incurred. Where they are paid in Bitcoin, the same disposal mechanics as network fees apply.

For presentation, most companies show trading, network and custody costs within operating expenses, separate from remeasurement gains and losses. Keeping costs out of the remeasurement line makes the fair value movement easier to read.

Tax considerations

Tax treatment follows local rules, which may differ from the accounting. Points to raise with advisers include:

  • Whether acquisition costs are added to the tax cost basis or deducted separately.
  • Whether paying a fee in Bitcoin is itself a taxable disposal.
  • Whether custody and network fees are deductible, and when.

Companies should take local tax advice in each jurisdiction.

How The Bitcoin World helps

We help finance teams structure execution so that price, spread, fees and settlement costs are reported separately on every trade, ready for accounting and best execution review. Execution and custody are carried out by licensed third-party institutions. See our OTC liquidity and corporate treasury services.

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