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openaccountants/skills/uk-crypto-tax.md

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uk-crypto-tax.md445 lines19.9 KB
v10United Kingdom
Not yet verified by an accountantContact accountant
1---
2name: uk-crypto-tax
3description: >
4 Use this skill whenever asked about UK cryptocurrency or digital asset taxation. Trigger on phrases like "crypto tax UK", "Bitcoin UK tax", "HMRC crypto", "cryptoassets UK", "crypto capital gains UK", "staking tax UK", "mining tax UK", "NFT tax UK", "DeFi tax UK", "SA108 crypto", "crypto CGT", "bed and breakfasting crypto", "S104 pool", "crypto loss UK", "Coinbase UK tax", "Binance UK tax", "Revolut crypto UK", "crypto income UK", "DAC8 UK", "HMRC cryptoassets manual", or any question about the income tax, capital gains tax, or reporting treatment of cryptocurrency, tokens, or digital assets for UK tax residents. Covers HMRC's Cryptoassets Manual (CRYPTO10000+), S104 pooling, same-day and 30-day matching rules, DeFi lending/staking, NFTs, mining, and SA108 reporting. ALWAYS read this skill before touching any UK crypto work.
5version: 1.0
6jurisdiction: GB
7tax_year: 2025
8category: crypto
9depends_on:
10 - uk-capital-gains-sa108
11 - uk-income-tax-sa100
12verified_by: pending
13---
14 
15# UK Crypto / Digital Assets Tax Skill v1.0
16 
17---
18 
19## Section 1 — Quick Reference
20 
21| Field | Value |
22|---|---|
23| Country | United Kingdom (England, Wales, Northern Ireland; Scotland has different income tax rates) |
24| Tax | Capital Gains Tax (CGT) and Income Tax on cryptoassets |
25| Currency | GBP (all values must be converted to GBP at the transaction date) |
26| Tax year | 6 April – 5 April (2025/26 = 6 Apr 2025 – 5 Apr 2026) |
27| Primary authority | HMRC Cryptoassets Manual (CRYPTO10000+); Taxation of Chargeable Gains Act 1992 (TCGA 1992); Income Tax Act 2007 (ITA 2007); Income Tax (Trading and Other Income) Act 2005 (ITTOIA 2005) |
28| Tax authority | HM Revenue & Customs (HMRC) |
29| Filing portal | HMRC Self Assessment Online / Government Gateway |
30| CGT annual exempt amount | £3,000 (2025/26) |
31| CGT rates (individuals) | 18% (basic-rate taxpayer) / 24% (higher/additional-rate taxpayer) |
32| Income tax rates (mining/staking) | 20% / 40% / 45% (England, Wales, NI) |
33| Personal allowance | £12,570 (2025/26) |
34| Cost basis method | Section 104 pooling (TCGA 1992 S104), subject to same-day and 30-day matching rules |
35| Anti-avoidance | 30-day bed-and-breakfasting rule (TCGA 1992 S106A) |
36| Reporting form | SA108 (Capital Gains Summary) supplementary to SA100 |
37| Filing deadline | 31 January following end of tax year (31 Jan 2027 for 2025/26) for online filing |
38| Exchange reporting | No mandatory exchange reporting yet; DAC8/CARF from 2026 |
39| Validated by | Pending — requires sign-off by a UK chartered accountant or tax adviser |
40| Skill version | 1.0 |
41 
42### HMRC Cryptoasset Classification (CRYPTO10000+)
43 
44| Asset Type | HMRC Classification | CGT Treatment | Income Tax Treatment |
45|---|---|---|---|
46| Exchange tokens (BTC, ETH, LTC) | Tokens used as means of payment | Subject to CGT on disposal | Mining/staking/airdrops = income |
47| Utility tokens | Tokens providing access to a service | Subject to CGT on disposal | Trading profits = income if traded |
48| Security tokens | Tokens providing rights like shares/debt | Subject to CGT on disposal | May also attract income tax on returns |
49| Stablecoins (USDT, USDC) | Exchange tokens pegged to fiat | Subject to CGT on disposal (gain usually negligible) | N/A |
50| NFTs | Non-fungible tokens | Subject to CGT on disposal | Creator sales = trading income |
51 
52### Conservative Defaults
53 
54| Ambiguity | Default |
55|---|---|
56| Unknown cost basis | Zero cost basis (maximises gain) — STOP if material |
57| Unknown whether trading or investment | Treat as investment (CGT) unless clear badges of trade |
58| Unknown token classification | Treat as exchange token (subject to CGT) |
59| Unknown FMV at receipt | Use CoinGecko/CoinMarketCap daily close in GBP |
60| Unknown whether income or capital DeFi return | Income (higher rate treatment) |
61| Airdrop with no clear service performed | Income at FMV on receipt |
62 
63---
64 
65## Section 2 — Classification Rules: Capital Gains vs Income
66 
67### When CGT applies (most individual crypto users)
68 
69HMRC treats cryptoassets as property, not currency. Each disposal triggers a CGT computation. A "disposal" includes (CRYPTO22100):
70 
71- Selling tokens for fiat
72- Exchanging tokens for a different type of token (crypto-to-crypto swap)
73- Using tokens to pay for goods or services
74- Giving away tokens (except to spouse/civil partner)
75 
76**NOT a disposal:**
77- Transferring between own wallets
78- Using a mixer/tumbler where same token type returned
79- Gifting to spouse/civil partner (no gain, no loss — transferee inherits cost basis)
80 
81### When Income Tax applies
82 
83| Activity | Tax Treatment | Authority |
84|---|---|---|
85| Mining (hobbyist) | Miscellaneous income at FMV when received | ITTOIA 2005 S687; CRYPTO21200 |
86| Mining (commercial/business) | Trading income; expenses deductible | ITTOIA 2005 Part 2; CRYPTO21200 |
87| Staking rewards | Miscellaneous income at FMV when received | CRYPTO21200 |
88| Airdrops (for service/action) | Miscellaneous income at FMV when received | CRYPTO21250 |
89| Airdrops (unsolicited, no action) | Not income on receipt; CGT on disposal from zero cost | CRYPTO21250 |
90| Employer pays salary in crypto | Employment income at FMV; PAYE/NIC applies | CRYPTO21100 |
91| DeFi yield (income returns) | Miscellaneous income or trading income | CRYPTO61200 |
92 
93### Income Tax Rates (2025/26 — England, Wales, NI)
94 
95| Band | Taxable Income | Rate |
96|---|---|---|
97| Personal Allowance | Up to £12,570 | 0% |
98| Basic rate | £12,571 – £50,270 | 20% |
99| Higher rate | £50,271 – £125,140 | 40% |
100| Additional rate | Over £125,140 | 45% |
101 
102Source: Finance Act 2025 s.2; GOV.UK Income Tax rates 2025/26.
103 
104---
105 
106## Section 3 — Capital Gains Tax Rate Table
107 
108### CGT Rates for Cryptoassets (2025/26)
109 
110| Taxpayer Status | Rate |
111|---|---|
112| Basic-rate taxpayer (gains within basic-rate band) | 18% |
113| Higher-rate / additional-rate taxpayer | 24% |
114| Trustees / personal representatives | 24% |
115| Annual exempt amount (individuals) | £3,000 |
116| Annual exempt amount (most trustees) | £1,500 |
117 
118Source: TCGA 1992; GOV.UK Capital Gains Tax rates and allowances (updated for 2025/26).
119 
120**Note:** Prior to 30 October 2024, rates were 10%/20%. For 2024/25, the year was split: 10%/20% (6 Apr – 29 Oct 2024) and 18%/24% (30 Oct 2024 – 5 Apr 2025). For 2025/26 onwards, the full year is 18%/24%.
121 
122### CGT Computation
123 
124```
125Disposal proceeds (GBP at date of disposal)
126 LESS: Allowable cost (from S104 pool, same-day rule, or 30-day rule)
127 LESS: Incidental costs of disposal (exchange fees, gas fees)
128 = Gain or (Loss)
129 
130Total gains for the year
131 LESS: Allowable losses of the year
132 LESS: Losses brought forward (only to reduce gains to annual exempt amount)
133 LESS: Annual exempt amount (£3,000)
134 = Taxable gains
135 
136Tax = Taxable gains × 18% or 24%
137```
138 
139---
140 
141## Section 4 — Cost Basis: Section 104 Pooling and Matching Rules
142 
143HMRC requires a specific matching order for cryptoasset disposals (CRYPTO22200):
144 
145### Matching Order (mandatory priority)
146 
147| Priority | Rule | Reference |
148|---|---|---|
149| 1st | **Same-day rule** — match against tokens of the same type acquired on the same day | TCGA 1992 S105(1) |
150| 2nd | **30-day rule (bed-and-breakfasting)** — match against tokens of the same type acquired within 30 days AFTER the disposal | TCGA 1992 S106A |
151| 3rd | **S104 pool** — match against the average cost of the S104 pool of that token type | TCGA 1992 S104 |
152 
153### S104 Pool Mechanics
154 
155The S104 pool is a running weighted-average cost pool for each token type. Each time you acquire tokens, the pool quantity and pool cost increase. Each time you dispose of tokens (not matched by same-day or 30-day rules), the cost of disposal is the proportionate share of the pool cost.
156 
157```
158Pool cost per token = Total pool cost ÷ Total pool quantity
159Cost of disposal = Tokens disposed × Pool cost per token
160```
161 
162| Permitted Method | Status |
163|---|---|
164| S104 pooling (weighted average) | MANDATORY for most disposals |
165| FIFO | NOT permitted (except for specific share identification — not applicable to crypto) |
166| LIFO | NOT permitted |
167| Specific identification | NOT permitted for crypto |
168 
169### What is included in cost basis
170 
171- Purchase price in GBP (converted at exchange rate on acquisition date)
172- Exchange fees and commissions on acquisition
173- Gas/network fees on acquisition (CRYPTO22280)
174- Note: token fees paid as gas are themselves a disposal at market value
175 
176---
177 
178## Section 5 — DeFi, Staking, Mining, and Airdrops
179 
180### 5.1 DeFi Lending (CRYPTO61000+)
181 
182HMRC published DeFi guidance in February 2022 (Cryptoassets Manual CRYPTO61000 onwards) and consulted on reforms in August 2022.
183 
184| DeFi Activity | Tax Treatment | Key Question |
185|---|---|---|
186| Lending tokens to a protocol | **Disposal** if beneficial ownership transfers; **not a disposal** if beneficial ownership retained | Does the borrower/platform have free use of the tokens? |
187| Receiving LP tokens in return | Exchange of tokens = disposal of deposited tokens, acquisition of LP tokens at FMV | CRYPTO61620 |
188| Interest/yield received | Miscellaneous income at FMV on receipt (NOT interest — crypto is not money) | CRYPTO61200 |
189| Withdrawal from protocol | Disposal of LP tokens, reacquisition of underlying | FMV at withdrawal |
190| Impermanent loss | Crystallised on withdrawal — reflected in gain/loss on LP token disposal | No separate relief |
191 
192**Government consultation (2022):** Proposed elective regime to disregard DeFi disposals for CGT until economic disposal. Not yet enacted as of 2025/26 — current rules apply.
193 
194### 5.2 Staking
195 
196| Aspect | Treatment |
197|---|---|
198| Proof-of-stake validation rewards | Miscellaneous income at FMV when received (CRYPTO21200) |
199| Cost basis of staking reward | FMV at receipt date (becomes acquisition cost for CGT) |
200| Subsequent sale of staking reward | CGT on gain from FMV cost basis |
201| Staking-as-a-service provider | Trading income; business expenses deductible |
202 
203### 5.3 Mining
204 
205| Aspect | Treatment |
206|---|---|
207| Hobby mining | Miscellaneous income at FMV when mined (CRYPTO21200) |
208| Business mining | Trading income; expenses deductible (electricity, hardware depreciation, rent) |
209| Cost basis of mined tokens | FMV at date mined |
210| Subsequent sale of mined tokens | CGT on gain from FMV cost basis |
211 
212### 5.4 Airdrops (CRYPTO21250)
213 
214| Scenario | Treatment |
215|---|---|
216| Airdrop received in return for a service or action | Miscellaneous income at FMV on receipt |
217| Unsolicited airdrop (no action required) | NOT income on receipt; zero cost basis; full gain taxable as CGT on disposal |
218| Airdrop with negligible value | Record at zero; CGT on disposal |
219 
220### 5.5 Hard Forks
221 
222| Scenario | Treatment |
223|---|---|
224| New tokens from fork (e.g. BTC → BCH) | NOT a disposal of original tokens; new tokens received at zero cost (no acquisition cost) |
225| Sale of forked tokens | Full proceeds = gain (zero cost basis) |
226| Apportioning original cost | HMRC does not require cost apportionment for hard forks — new token cost = £0 |
227 
228---
229 
230## Section 6 — NFT Treatment
231 
232| Event | Tax Treatment |
233|---|---|
234| Purchase of NFT (collector) | Acquisition — record cost basis including gas fees |
235| Sale of NFT (collector) | CGT on disposal (proceeds minus S104 pool cost of NFT) |
236| Creation and primary sale of NFT (artist) | Trading income if business; miscellaneous income if one-off |
237| Royalty income from secondary sales | Miscellaneous income at FMV on receipt |
238| NFT-for-NFT swap | Disposal of both NFTs; each at FMV |
239| NFT becomes worthless | Negligible value claim possible (TCGA 1992 S24(2)) — triggers loss |
240| VAT on NFT | Potentially subject to VAT at 20% if seller is VAT-registered (digitally supplied service) |
241 
242HMRC treats NFTs the same as any other cryptoasset for CGT purposes (CRYPTO22100). The same S104 pooling and matching rules apply per individual NFT (each unique NFT is its own asset — no pooling between different NFTs).
243 
244---
245 
246## Section 7 — Reporting Requirements
247 
248### 7.1 Self Assessment Forms
249 
250| Form | Purpose |
251|---|---|
252| SA100 | Main Self Assessment tax return |
253| SA108 | Capital Gains Summary supplementary page |
254 
255### 7.2 When SA108 is required
256 
257You must file SA108 if any of the following apply (2025/26):
258- Total disposal proceeds from all assets exceed £50,000
259- Chargeable gains before losses exceed £3,000 (the annual exempt amount)
260- You wish to claim an allowable capital loss
261- Losses brought forward are being used
262 
263### 7.3 Key Deadlines
264 
265| Deadline | Date |
266|---|---|
267| End of tax year 2025/26 | 5 April 2026 |
268| Paper SA100 filing deadline | 31 October 2026 |
269| Online SA100 filing deadline | 31 January 2027 |
270| Payment deadline | 31 January 2027 |
271| Payments on account | 31 January and 31 July |
272 
273### 7.4 Exchange Reporting
274 
275As of 2025/26, there is **no mandatory exchange reporting** obligation in the UK for crypto platforms. However:
276- **DAC8 (EU)** and **CARF (OECD)** will require crypto-asset service providers to report user transaction data to HMRC from **2026**
277- HMRC can and does issue information notices to UK exchanges under existing powers
278- Voluntary disclosure is strongly recommended
279 
280### 7.5 Record-Keeping
281 
282| Requirement | Detail |
283|---|---|
284| Retention period | At least 5 years after the 31 January filing deadline (effectively ~6 years from end of tax year) |
285| Records to maintain | Full transaction logs from all exchanges, wallet addresses, S104 pool calculations, staking/mining logs, DeFi protocol records |
286| Format | CSV exports preferred; screenshots acceptable as backup; on-chain records (block explorer links) recommended |
287 
288---
289 
290## Section 8 — Loss Offset and Carry-Forward Rules
291 
292### 8.1 Capital Losses
293 
294| Rule | Detail | Authority |
295|---|---|---|
296| In-year offset | Allowable losses MUST be set against gains of the same tax year first | TCGA 1992 S2 |
297| Carry-forward | Unused losses can be carried forward indefinitely | TCGA 1992 S2(2) |
298| Carry-forward limitation | Carried-forward losses can only reduce gains to the annual exempt amount (£3,000) | TCGA 1992 S3 |
299| Carry-back | NOT permitted (except on death) | — |
300| Reporting deadline | Losses MUST be reported to HMRC within **4 years** of the end of the tax year in which they arose | TCGA 1992 S16(2A) |
301| Negligible value claim | For tokens that become worthless — treated as disposal and reacquisition at negligible value, crystallising a loss | TCGA 1992 S24(2) |
302 
303### 8.2 Income Losses (Mining/Trading)
304 
305- Trading losses from crypto mining/staking business may be offset against other income under ITA 2007 S64
306- Miscellaneous income losses can only offset miscellaneous income of the same type
307 
308### 8.3 Critical: 4-Year Loss Claim Window
309 
310If you do not report a capital loss within 4 years of the end of the tax year in which it arose, the loss is permanently lost. For a loss arising in 2025/26, the deadline is 5 April 2030.
311 
312---
313 
314## Section 9 — Anti-Avoidance: Bed-and-Breakfasting and Wash Sale Rules
315 
316### 9.1 The 30-Day Rule (TCGA 1992 S106A)
317 
318If a taxpayer disposes of tokens and reacquires tokens of the **same type** within **30 days** after the disposal, the disposal is matched to the reacquisition (not the S104 pool). This prevents:
319 
320- Selling to crystallise a loss and immediately rebuying
321- Selling to use the annual exempt amount and immediately rebuying
322 
323| Element | Detail |
324|---|---|
325| Window | 30 calendar days after the disposal |
326| Scope | Same token type only (selling BTC and buying ETH within 30 days is fine) |
327| Effect on loss | Loss is effectively deferred — cost of reacquired tokens takes on the cost of the original disposal |
328| Workaround ("Bed and ISA") | Sell, rebuy inside a spouse's account or ISA wrapper — but HMRC may challenge if artificial |
329 
330### 9.2 Same-Day Rule (TCGA 1992 S105)
331 
332If tokens are both acquired and disposed of on the same day, the disposal is matched to the same-day acquisition first.
333 
334### 9.3 General Anti-Abuse Rule (GAAR)
335 
336The GAAR (Finance Act 2013 Part 5) may apply to artificial crypto tax avoidance arrangements.
337 
338---
339 
340## Section 10 — Worked Examples
341 
342### Example 1 — Simple BTC Sale, CGT Computation
343 
344**Input:** UK tax resident. Bought 2 BTC at £20,000 each in January 2024. Sold 1 BTC at £45,000 in August 2025. No other disposals. Exchange fees: £50 on acquisition, £75 on disposal. Basic-rate taxpayer.
345 
346**Computation:**
347```
348S104 pool:
349 2 BTC acquired at £20,000 each = £40,000 + £50 fees = £40,050
350 Pool cost per BTC = £40,050 ÷ 2 = £20,025
351 
352Disposal of 1 BTC:
353 Proceeds: £45,000
354 LESS disposal fees: £75
355 Net proceeds: £44,925
356 LESS S104 cost: £20,025
357 Gain: £24,900
358 
359 LESS annual exempt amount: £3,000
360 Taxable gain: £21,900
361 
362 CGT at 18% (basic-rate): £3,942
363 
364S104 pool after disposal: 1 BTC, cost £20,025
365```
366 
367### Example 2 — 30-Day Rule Blocks Loss
368 
369**Input:** UK tax resident. S104 pool: 5 ETH, total cost £10,000 (£2,000 per ETH). Sells 5 ETH at £1,500 each (£7,500) on 1 November 2025. Rebuys 5 ETH at £1,600 each (£8,000) on 20 November 2025 (within 30 days).
370 
371**Computation:**
372```
373Without 30-day rule:
374 Proceeds: £7,500, Cost: £10,000, Loss: (£2,500)
375 
376With 30-day rule (mandatory):
377 Disposal matched to 30-day reacquisition
378 Proceeds: £7,500
379 Matched cost: £8,000 (the reacquisition cost)
380 Loss: (£500)
381 
382 The loss is DEFERRED — the new S104 pool now holds 5 ETH at cost £10,000
383 (£8,000 reacquisition + £2,000 excess from original pool minus matched amount)
384 
385 Net effect: loss is deferred, not eliminated
386```
387 
388### Example 3 — Staking Income + Subsequent CGT
389 
390**Input:** UK tax resident. Received 0.5 ETH staking rewards over 2025/26. Total FMV at each receipt: £1,800. Sold 0.5 ETH in March 2026 at £2,200. Higher-rate taxpayer.
391 
392**Computation:**
393```
394Income tax on staking (miscellaneous income):
395 £1,800 × 40% (higher rate) = £720
396 
397Cost basis of staked ETH: £1,800
398 
399CGT on disposal:
400 Proceeds: £2,200
401 Cost basis: £1,800
402 Gain: £400
403 
404 If within annual exempt amount (£3,000): no CGT
405 Total tax: £720 income tax only
406```
407 
408---
409 
410## Self-Checks
411 
412- [ ] Have all disposals been identified (sells, swaps, crypto-to-crypto, payments for goods/services)?
413- [ ] Have same-day and 30-day matching rules been applied before the S104 pool?
414- [ ] Is the S104 pool maintained separately for each token type?
415- [ ] Have mining/staking/airdrop receipts been included as income?
416- [ ] Has the £3,000 annual exempt amount been applied correctly?
417- [ ] Have losses been reported within the 4-year window?
418- [ ] Is the correct CGT rate applied (18% or 24%) based on the taxpayer's total income?
419- [ ] Are all values converted to GBP at the transaction date?
420- [ ] Has SA108 been completed if thresholds are exceeded?
421- [ ] Have DeFi transactions been analysed for beneficial ownership transfer?
422 
423---
424 
425## PROHIBITIONS
426 
427- NEVER assume crypto is tax-free in the UK — disposals are subject to CGT
428- NEVER apply FIFO, LIFO, or specific identification — the UK REQUIRES S104 pooling with same-day and 30-day matching
429- NEVER treat crypto-to-crypto swaps as non-taxable — they ARE disposals (CRYPTO22100)
430- NEVER treat staking/mining income as capital gains — it is income (CRYPTO21200)
431- NEVER ignore the 30-day bed-and-breakfasting rule when matching disposals
432- NEVER forget to convert all values to GBP at the transaction-date exchange rate
433- NEVER allow losses to go unreported beyond the 4-year claim window
434- NEVER treat transfers between own wallets as disposals
435- NEVER classify DeFi returns as "interest" — crypto is not money (CRYPTO61200)
436- NEVER present crypto tax positions as definitive — always label as estimated and flag for professional review
437 
438---
439 
440## Disclaimer
441 
442This skill and its outputs are provided for informational and computational purposes only and do not constitute tax, legal, or financial advice. Open Accountants and its contributors accept no liability for any errors, omissions, or outcomes arising from the use of this skill. All outputs must be reviewed and signed off by a qualified professional (such as a CPA, EA, tax attorney, or equivalent licensed practitioner in your jurisdiction) before filing or acting upon.
443 
444The most up-to-date, verified version of this skill is maintained at [openaccountants.com](https://openaccountants.com). Log in to access the latest version, request a professional review from a licensed accountant, and track updates as tax law changes.
445 

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About

Use this skill whenever asked about UK cryptocurrency or digital asset taxation. Trigger on phrases like "crypto tax UK", "Bitcoin UK tax", "HMRC crypto", "cryptoassets UK", "crypto capital gains UK", "staking tax UK", "mining tax UK", "NFT tax UK", "DeFi tax UK", "SA108 crypto", "crypto CGT", "bed and breakfasting crypto", "S104 pool", "crypto loss UK", "Coinbase UK tax", "Binance UK tax", "Revolut crypto UK", "crypto income UK", "DAC8 UK", "HMRC cryptoassets manual", or any question about the income tax, capital gains tax, or reporting treatment of cryptocurrency, tokens, or digital assets for UK tax residents. Covers HMRC's Cryptoassets Manual (CRYPTO10000+), S104 pooling, same-day and 30-day matching rules, DeFi lending/staking, NFTs, mining, and SA108 reporting. ALWAYS read this skill before touching any UK crypto work.

GBty-2025

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