Cryptoassets (which might also be referred to as 'tokens' or 'cryptocurrency') are cryptographically secured digital representations of value or contractual rights1.
This article discusses how to determine the beneficial owner of a cryptoasset and the location (situs) of cryptoassets for capital gains tax (CGT) purposes. For a summary of the UK tax treatment of various cryptoasset transactions, see C6.105. For commentary on transactions in cryptoassets that are subject to CGT, see C6.117–C6.118.
For the situs of cryptoassets for inheritance tax and income tax, see C6.122 and C6.123 respectively.
For the definition of cryptoassets and cryptoasset transactions, see C6.103–C6.104. For a glossary of key terms associated with cryptoassets, see C6.102.
Determining the situs of the cryptoassets for CGT purposes
The situs of the cryptoasset for CGT is important because it determines whether the gain is taxable or the loss allowable in the UK. The importance of situs is explained in C1.604.
In HMRC's view, the domestic determination of the situs of a cryptoasset for CGT purposes depends on whether the cryptoasset is a digital
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Web page updated on 17 Mar 2025 17:21