BCMS

Bitkaya Accounting Treatment in Odoo SOP

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Purpose

Register the Bitkaya Accounting Memorandum as the implementation SOP for recording, valuing, reconciling and reporting Bitkaya’s crypto-asset trading and related services in Odoo.

This SOP is subordinate to PROC-FIN-002 Maintain Books Records Reconciliations and Financial Close. It also implements tax configuration, annual reporting and financial-movement controls through the linked FIN procedures.

Source Document

  • Document title: Accounting Memorandum - Bitkaya Accounting Treatment in Odoo
  • Version: 1.0
  • Date shown in document: 2026-03-25
  • Prepared for: Auditors and Accounting Professionals
  • Prepared by: Cees Quirijns
  • Approval shown in document: none
  • Permanent artifact: 20260325 Bitkaya Accounting Memorandum.pdf
  • Artifact SHA-256: e75bd493f5c143152206a6923dafdcd98fe9a2388a5fa5bced687ff51d387782
  • Document metadata creation date: 2026-03-26

System of Record

SYS-FIN-001 Odoo Accounting ERP is the central accounting system of record for transaction processing, crypto-asset inventory, invoicing, settlements, accounting and financial reporting.

Banking platforms, blockchain wallets, DEX activity and the separate custody platform remain external systems. Their balances and movements must be reconciled to Odoo or to the designated custody ledger as applicable. Odoo must not be treated as the custody verification system for client-owned virtual assets.

Operating Treatment

Principal Trading

  • Record Bitkaya as principal where the approved accounting analysis confirms that Bitkaya controls the crypto-assets before resale, bears inventory and price risk and determines pricing.
  • Record gross trading revenue and cost of goods sold rather than commission revenue when the principal conclusion applies.
  • Preserve the transaction, counterparty, price, settlement, wallet and accounting evidence supporting each trade.
  • Reassess the principal-versus-agent conclusion after a material product, contract, settlement or business-model change.

Crypto-Asset Inventory

  • Configure supported Bitkaya-owned crypto-assets as storable inventory products in Odoo.
  • Record purchases at the agreed transaction value with the corresponding settlement liability.
  • Record sales at transaction price and recognize cost of goods sold using weighted average cost.
  • Keep realized margin as the difference between revenue and cost of goods sold rather than a separate accounting line.
  • Reconcile Odoo inventory quantities to Bitkaya-owned blockchain wallet and custodial records and investigate every unexplained difference.
  • Keep client-owned custody assets outside Bitkaya inventory and separate from Bitkaya-owned wallet positions.

Omzetbelasting Configuration

  • Configure crypto trading products without OB only where the approved tax position supports exempt treatment of the trading spread.
  • Configure separately charged handling or service fees with the current applicable OB treatment and show taxable and non-taxable components clearly on invoices.
  • Assess services received from non-resident suppliers for reverse-charge OB and document tax recognition and recoverability.
  • Review tax mappings after product, supplier, client-location, invoice, legal or rate change.

Territorial Profit Tax

  • Maintain controlled DCC, FCC and NCC account or analytic classifications in Odoo.
  • Document the activity, location, substance and cost-allocation basis for domestic and foreign treatment.
  • Reconcile the tax allocation to the general ledger and approved tax return workpapers.
  • Obtain external tax validation before relying on a material territorial allocation or changing the allocation method.

Bank and DEX Matching

  • Match each crypto-fiat trade to the corresponding bank receipt or payment using amount, counterparty and timing.
  • Record crypto-crypto movements through the designated DEX clearing account and reconcile the complete chain of inflows and outflows.
  • Investigate unmatched, duplicate, reversed, stale or unsupported movements before financial close.
  • Apply the authorization, restriction and exception requirements of PROC-FIN-006 Control Payments Receipts Reconciliations and Finance Exceptions.

Reporting-Date Valuation

  • Preserve weighted average cost as the transactional inventory cost basis.
  • Record any approved reporting-date valuation adjustment in the separate Inventory Valuation Adjustment account so the underlying cost records remain traceable.
  • Document the pricing source, timestamp, observable market, asset, quantity, carrying amount, market amount, materiality, preparer, reviewer and approval.
  • Distinguish realized trading margin from unrealized valuation movement.
  • Do not post an upward or downward mark-to-market adjustment until the applicable accounting framework and tax treatment have been independently confirmed.

Client Custody

  • Keep client-owned assets off Bitkaya’s balance sheet only where the approved legal and accounting analysis confirms no transfer of control, ownership or economic exposure.
  • Maintain separately identifiable client wallets and segregate them from Bitkaya-owned inventory.
  • Perform custody reconciliation in the designated wallet platform, not in Odoo, and provide the summarized financial-reporting interface required for complete disclosure.
  • Treat insolvency-ring-fencing and estate-exclusion statements as subject to applicable legal and contractual arrangements and the evidence required by ISS-SAFU-001 Confirm Safeguarding Architecture Legal Protections and Operating Evidence.

Required Review and Approval

Before this SOP moves from review to implemented or operational, retain approval of:

  • principal-versus-agent and gross-versus-net revenue treatment from a qualified accounting professional;
  • inventory classification, weighted average cost and reporting-date valuation treatment under the applicable accounting framework;
  • OB exemption, service-fee treatment, reverse charge and territorial cost allocation from a qualified Curaçao tax adviser;
  • client-asset ownership, segregation and insolvency treatment from qualified legal counsel;
  • the Odoo chart of accounts, product taxes, analytic classifications, clearing accounts, journal permissions and valuation accounts; and
  • the reconciliation, manual journal, period-close and change-control evidence required by the linked FIN controls.

Evidence

  • Approved accounting and tax position papers
  • Odoo product, tax, account and analytic configuration export
  • Odoo role and access review
  • Sample purchase, sale, settlement and invoice audit trails
  • Weighted average cost and inventory valuation reports
  • Odoo-to-wallet, Odoo-to-bank and DEX clearing reconciliations
  • Tax mapping and DCC/FCC/NCC allocation workpapers
  • Reporting-date valuation calculation and approval
  • Custody ledger-to-blockchain reconciliation and financial-reporting interface
  • Manual journal, exception, configuration-change and period-close approvals

Assurance

  • Document registered: yes
  • Artifact integrity captured: yes
  • SOP approval status: not confirmed in the document
  • Odoo operating configuration independently verified: no
  • Accounting, tax and legal judgments independently verified: no
  • Overall status: implementation memorandum registered for review; operation and professional conclusions remain subject to ISS-FIN-001 Confirm Finance and Tax Sources Thresholds Systems and Operating Evidence

History

  • 2026-07-26: Registered the Accounting Memorandum version 1.0 as the Odoo implementation SOP subordinate to PROC-FIN-002.

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