If it looks like a duck, swims like a duck, and quacks like a duck…

Cryptocurrency can create practical accounting questions for a Dutch company. A Dutch BV may hold crypto as an investment, receive crypto as payment, use it in treasury activity, or be part of a group where crypto-related transactions are managed outside the Netherlands.

For foreign-owned Dutch entities, the issue is often not only the asset itself. The difficulty is usually the accounting trail: ownership, wallet control, transaction history, valuation, exchange records and how the crypto position connects to the Dutch administration.

This article explains practical accounting points companies should consider when cryptocurrency appears in the records of a Dutch entity.

Cryptocurrency is not the same as cash

A common mistake is to treat cryptocurrency like a bank balance. From an accounting perspective, that is usually too simple.

The Dutch Accounting Standards Board has previously considered the treatment of cryptocurrencies and noted that cryptocurrencies are not cash or cash equivalents.

That matters because a crypto balance usually needs separate consideration. Questions include:

• Who controls the wallet?
• What was the purpose of acquiring the crypto?
• Is the crypto held for investment, trading, payment, treasury or another purpose?
• How is fair value or cost supported?
• Are transaction records complete?
• Are gains and losses properly identified?

For a Dutch BV, the accounting treatment should follow the facts and circumstances. A small passive holding is different from frequent trading, customer payments, mining, staking, token issuance or crypto activity managed as part of a wider group business.

The accounting record needs to show more than a wallet balance

A wallet balance alone is not enough accounting evidence.

The administration should normally be able to support:

• opening balances
• purchases
• sales
• transfers between wallets
• exchange transactions
• transaction fees
• closing balances
• valuation at reporting date
• evidence of ownership or control

This can become difficult when transactions move across several exchanges, private wallets or group-controlled addresses. It becomes even harder when crypto assets were acquired before the Dutch accounting process was properly set up.

For accounting purposes, the practical question is not only “how much crypto does the company hold?” The question is whether the Dutch entity has a reliable and auditable transaction trail.

Valuation needs a clear method

Crypto prices can move significantly. That makes valuation important.

For a Dutch company, the accounting file should document how the crypto position is valued and which source was used. For example:

• exchange rate source
• valuation date and time
• currency conversion into EUR
• treatment of transaction fees
• method used for disposals
• supporting exchange or wallet reports

The company should avoid changing the method from period to period without a clear reason. Consistency matters, especially when annual accounts are prepared or when the Dutch entity reports into a parent company.

Foreign-owned Dutch BVs need to align local and group reporting

Crypto positions often sit inside a wider international structure. The parent company may apply a different reporting framework, may hold the exchange account centrally, or may expect the Dutch entity to report crypto balances in a particular way.

That can create practical questions:

• Is the crypto legally held by the Dutch BV or by another group company?
• Are wallet addresses controlled locally or centrally?
• Are intercompany balances created by transfers?
• Does the Dutch administration match the parent-company reporting?
• Are unrealised gains or losses treated consistently?

If these points are not clarified early, the annual accounts process can become unnecessarily difficult.

Crypto and tax should not be treated as an afterthought

This article is about accounting, not tax advice. But crypto positions can also create tax questions.

The Dutch tax authorities publish positions on crypto in different contexts. For individuals, crypto is generally treated as an asset in box 3 unless there is a business or other taxable activity; the Belastingdienst also notes that crypto may be relevant differently where there is an enterprise or activity.

For companies, the relevant analysis depends on the company’s facts. A Dutch BV holding crypto should therefore make sure the accounting records are sufficient for tax review as well as annual accounts preparation.

Common problems we see in practice

Crypto-related accounting problems often come from missing structure, not from the asset itself.

Common issues include:

• no clear distinction between company and personal wallets
• missing exchange exports
• transfers recorded as purchases or sales
• transaction fees ignored
• no EUR valuation support at reporting date
• group wallets used without clear ownership documentation
• no reconciliation between wallet balances and accounting records
• unrealised gains or losses not considered

These issues are far easier to fix early than at year-end.

Practical checklist for Dutch companies holding crypto

A Dutch company with crypto exposure should keep at least the following:

• wallet addresses used by the company
• exchange account statements
• transaction exports for the full period
• evidence of ownership or control
• EUR value at acquisition and disposal
• EUR value at reporting date
• documentation of valuation source
• explanation of the purpose of the crypto holding
• reconciliation between wallet/exchange records and the accounting ledger

For foreign-owned Dutch entities, it is also useful to document who in the group controls the wallets and how the Dutch entity receives transaction information.

How Kanso Accounting helps

Kanso Accounting supports foreign-owned Dutch entities and international finance teams with Dutch accounting, VAT and compilation work.

Where cryptocurrency appears in the administration, we help bring structure to the accounting records. That includes understanding the transaction flow, identifying the records needed, aligning the Dutch administration with parent-company reporting, and preparing the information needed for annual accounts or compilation work.

Crypto does not need to make the accounting process chaotic. But it does require a clear record, a consistent valuation approach and early attention to ownership and transaction evidence.

Seel also RJ geeft commentaar op EFRAG DP over Crypto Assets – RJNet