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    TaxKilnUK tax guidance
    TaxKilnUK tax guidance

    Crypto + Digital Assets Tax → CGT on disposals + pooling

    UK CGT on Crypto Disposals — TCGA 1992 Pooling (Same-Day + 30-Day + s.104) + Post-30 Oct 2024 Rates

    TaxKiln framework

    Crypto Disposal Audit Trail

    TaxKiln's structured audit-trail framework for cryptoasset CGT — disposal-event classification (sale + swap + spend + gift + airdrop receipt) + section-104 pooling order (same-day → 30-day → s.104) + acquisition-cost methodology applied per disposal.

    Most crypto CGT mistakes arise not from the rates but from misclassified disposal events; the TaxKiln Crypto Disposal Audit Trail enforces a per-event walk — classification, then pooling order (same-day → 30-day → s.104), then acquisition cost — so every disposal carries its own auditable lineage rather than being collapsed into an annual aggregate.

    Crypto is a chargeable asset under TCGA 1992 (HMRC CRYPTO22000). Every disposal is a chargeable event — including selling for fiat, swapping one crypto for another, gifting (other than to a spouse / civil partner — s.58 TCGA 1992), and spending crypto on goods or services. Pooling rules from TCGA 1992 ss.104-106A apply in three layers: SAME-DAY (acquisitions on the same day as the disposal are matched first), 30-DAY 'bed-and-breakfasting' rule (acquisitions in the 30 days FOLLOWING disposal are matched next — anti-avoidance), then the s.104 POOL (everything else pooled at weighted-average cost). CGT rates from 30 October 2024 (Autumn Budget 2024): 18% within the basic-rate band; 24% above basic rate, including for trustees and personal representatives. The Annual Exempt Amount for 2025/26 is £3,000 for individuals and £1,500 for trustees + PRs. Companies do not use the 30-day rule; they apply TCGA 1992 s.107 (separate 9-day matching window) + corporate s.104-equivalent pool, with disposals taxed at the prevailing CT rate.

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    Guidance, not advice. We explain the rules, we don't assess your situation. Always seek financial or tax advice from your accountant, or contact HMRC. Read our editorial scope →

    In plain English

    Think of every disposal as creating a tax point. Selling BTC for GBP — disposal. Swapping BTC for ETH — disposal of BTC at sterling MV. Gifting crypto to a friend — disposal at MV (no consideration but s.17 TCGA 1992 deems MV between connected/non-arm's-length parties). Buying a coffee with crypto — disposal at MV. To compute gain/loss you need a base cost. The pooling rules tell you which acquisitions match a disposal: 1. SAME-DAY rule (s.105 TCGA 1992): any acquisitions made on the same calendar day as the disposal are matched first, at their actual cost. 2. 30-DAY 'bed-and-breakfasting' rule (s.106A): any acquisitions in the 30 days FOLLOWING the disposal are matched next (this is anti-avoidance — it stops you crystallising a loss by selling at a low price and immediately re-buying). 3. s.104 POOL: everything left is in the s.104 pool, which holds a weighted-average cost per unit. Most retail disposals match against the s.104 pool. The new rates from 30 October 2024 matter: a higher-rate individual disposing of crypto at a gain of £50,000 pays 24% on the £47,000 above the £3,000 AEA = £11,280. Before 30 October 2024 the higher rate was 20%, so the same gain would have been £9,400. Anything DISPOSED ON OR AFTER 30 October 2024 uses the new rates — even if acquired earlier. Companies hold crypto on capital account by default but holding-as-trading-stock can apply where activity = trade. Where capital, companies use TCGA 1992 s.107 — 9-day matching window not 30-day, plus a corporate-pool equivalent. Company chargeable gains taxed at the main CT rate (25% from April 2023, marginal relief band £50k-£250k for small-profits rate of 19%). Reporting: individuals report on SA108 Capital Gains pages if proceeds > £50,000 OR taxable gain (after losses + AEA) > £0. Below the threshold you may still want to file to crystallise carry-forward losses (TCGA 1992 s.16(2A) — claim by 4th anniversary of end of tax year of loss).

    How it works

    What counts as a disposal

    HMRC CRYPTO22000: disposal includes (a) sale of crypto for fiat; (b) exchange of one crypto for another (both legs are disposals); (c) using crypto to pay for goods/services (disposal at MV); (d) gift of crypto (s.17 TCGA 1992 deems MV between connected parties; no gain no loss between spouses/civil partners — s.58). NOT disposals: moving crypto between your own wallets (no change of beneficial ownership); pledging as collateral without transfer of beneficial ownership (fact-specific — see DeFi page).

    Pooling for individuals — three-tier matching

    Order of matching: (1) SAME-DAY (s.105) — acquisitions on the same calendar day as disposal matched first at actual cost. (2) 30-DAY b&b (s.106A) — acquisitions in the 30 days FOLLOWING disposal matched next at actual cost (anti-avoidance against same-asset loss harvesting). (3) s.104 POOL — everything else pooled, with weighted-average cost per unit recalculated on each net acquisition. Worked: hold 1 BTC pool cost £20k; buy 1 BTC for £30k → pool 2 BTC cost £50k, £25k/unit; sell 0.5 BTC for £20k → gain = £20k − (0.5 × £25k) = £7,500.

    CGT rates from 30 October 2024

    From 30 October 2024 disposals (Autumn Budget 2024 / FA 2025): 18% within unused basic-rate band; 24% above basic rate. Trustees + PRs: 24% (with reduced AEA £1,500). BADR remains separate at 14% from 6 April 2025 + 18% from 6 April 2026, but BADR rarely applies to retail crypto — it applies only to disposals of qualifying business assets where the holder was an officer/employee + 5% holder for 2 years, which excludes pure crypto holdings.

    Companies — TCGA 1992 s.107

    Companies do not use s.106A 30-day rule. They use s.107 — 9-day matching window for acquisitions following disposal — PLUS a corporate s.104-equivalent pool. Chargeable gains are taxed at the company's CT rate (25% main rate; small-profits 19% under £50k profits; marginal relief £50k-£250k). Crypto held by a company as trading stock (rather than investment) sits outside CGT entirely and is taxed under trading-profits rules — fact-sensitive analysis of frequency, organisation, intention.

    Annual Exempt Amount + losses

    AEA 2025/26: £3,000 individuals; £1,500 trustees + PRs. Allowable losses set against gains in same year FIRST, then carry forward (TCGA 1992 s.2(2)). Carry-forward loss claim must be made by 4th anniversary of end of tax year of loss (s.16(2A)) — so 2024/25 losses must be claimed by 5 April 2029. Spouse transfer at no gain/no loss (s.58) is a routine planning lever — transfer half to lower-band spouse before disposal to use both AEAs + lower rate band, provided substance + beneficial-ownership transfer is real.

    Negligible value claims (CRYPTO22500 + s.24 TCGA 1992)

    If crypto has become worthless (rugpull / hack / exchange collapse / dead chain), s.24 TCGA 1992 allows a negligible value claim deeming the asset disposed of at MV £0 → crystallises the loss without actual disposal. HMRC CRYPTO22500 sets the test: the asset must be of negligible value at the date of claim AND must have become so while owned by the taxpayer. Loss can be backdated up to 2 tax years prior. Pure 'I lost my private keys' is NOT a disposal per HMRC view — beneficial ownership unchanged — so negligible-value claim typically refused unless coin itself worthless.

    Who this applies to + key conditions

    Statute + manual references

    Primary: TCGA 1992 — chargeable assets (s.21 + s.22); pooling rules (ss.104-106A); companies (s.107); negligible value claim (s.24); spouse transfer no gain no loss (s.58); FA 2024 + FA 2025 rate setting from 30 October 2024.

    Related: TCGA 1992 s.21 — definition of chargeable asset; TCGA 1992 s.22 — disposal includes capital sum derived from asset; TCGA 1992 s.104 — pooled holdings of fungible assets; TCGA 1992 s.105 — same-day matching; TCGA 1992 s.106A — 30-day bed-and-breakfasting rule (individuals); TCGA 1992 s.107 — corporate 9-day matching; TCGA 1992 s.17 — disposals between connected persons at MV; TCGA 1992 s.58 — no gain / no loss transfer to spouse + civil partner; TCGA 1992 s.24 — negligible value claim (see also CRYPTO22500); FA 2024 + Autumn Budget 2024 / FA 2025 — CGT rates from 30 October 2024

    HMRC manual: CRYPTO10100 (overview); CRYPTO22000 (CGT framework); CRYPTO22150 (pooling); CRYPTO22300 (allowable costs); CRYPTO22500 (negligible value); CRYPTO22600 (location of cryptoassets)

    Case law: Marren v Ingles [1980] STC 500 — disposal point for deferred / contingent consideration; Drummond v HMRC [2009] EWCA Civ 608 — Ramsay principle on contrived loss generation

    Common mistakes + traps

    Worked example

    Aisha, higher-rate PAYE employee in Birmingham, holds ETH across two exchanges + a self-custody wallet

    During 2025/26 Aisha makes the following ETH transactions: 1 January 2026 — buys 5 ETH for £15,000; 14 March 2026 — sells 3 ETH for £12,000; 20 March 2026 — buys 2 ETH for £7,500; 31 March 2026 — sells 4 ETH for £18,000. She has no other crypto disposals + uses her full £3,000 AEA against the gains.

    1. Step 1 — Identify each disposal + sterling MV. 14 March disposal: 3 ETH for £12,000. 31 March disposal: 4 ETH for £18,000.
    2. Step 2 — Apply matching rules to 14 March disposal (3 ETH). SAME-DAY (s.105): no same-day acquisitions. 30-DAY b&b (s.106A): 20 March acquisition of 2 ETH for £7,500 is within 30 days following the 14 March disposal → match 2 ETH against £7,500. Remaining 1 ETH matches s.104 pool (5 ETH at £15,000 = £3,000/unit) → cost £3,000. Total cost matched: £7,500 + £3,000 = £10,500. Gain on 14 March disposal: £12,000 − £10,500 = £1,500.
    3. Step 3 — Update s.104 pool after 14 March + 20 March. Pool started 5 ETH at £15,000. The 1 ETH matched out leaves 4 ETH at £12,000. The 20 March acquisition was already matched under b&b → does NOT enter the pool. Pool now: 4 ETH at £12,000 = £3,000/unit.
    4. Step 4 — Apply matching rules to 31 March disposal (4 ETH). SAME-DAY: none. 30-DAY b&b: none (no acquisitions in following 30 days as at tax-year cut-off). Match 4 ETH to s.104 pool at £3,000/unit = £12,000. Gain on 31 March disposal: £18,000 − £12,000 = £6,000.
    5. Step 5 — Total chargeable gains 2025/26: £1,500 + £6,000 = £7,500. Less AEA £3,000 = £4,500 taxable.
    6. Step 6 — Apply CGT rates. Aisha is higher-rate → 24% on £4,500 = £1,080 CGT.
    7. Step 7 — SA108 reporting. Proceeds = £12,000 + £18,000 = £30,000 (below £50,000 threshold) BUT taxable gain > £0 → SA108 required. File by 31 January 2027 + pay £1,080 with balancing payment.
    8. Step 8 — Anti-charlatan note: a 'crypto tax specialist' quote of £2,800 to handle this is unwarranted; the pooling is mechanical + a £50-150/year crypto-tax-software annual subscription (Koinly / CoinTracker / CryptoTaxCalculator / Recap) produces the SA108 figures automatically + a £200-£500 accountant fee reviews them.

    Outcome: £1,080 CGT due 31 January 2027 on £4,500 taxable gain after AEA. Self-serve via crypto-tax software + SA108 — no specialist crypto retainer warranted at this volume.

    How this connects to the rest of the framework

    Income tax — mining, staking, airdrops →

    Receipts taxed as income create base cost for CGT on subsequent disposal at the market value used as income — avoids double tax.

    DeFi, NFTs, stablecoins + emerging →

    DeFi protocol interactions (lending / LP) often trigger disposals even though no fiat realised — pooling applies to each leg.

    CARF January 2026 →

    CARF reporting from 1 January 2026 means HMRC will reconcile platform-side data with SA108 disposals — accurate pooling now critical.

    Crypto via pension + company →

    Companies use TCGA 1992 s.107 (9-day matching) not s.106A — different pooling regime + CT rate not CGT rates.

    /self-assessment →

    SA108 Capital Gains pages are the reporting vehicle; thresholds + losses interact with the wider SA return.

    /tribunals-and-hmrc-enquiries/voluntary-disclosure-mechanisms →

    Prior-year unreported crypto gains best disclosed via DDS BEFORE CARF data lands at HMRC in 2027.

    Frequently asked questions

    What happens if I miss the Self Assessment deadline?+
    The Self Assessment deadline is 31 January (online filing) for the previous tax year. Miss it and HMRC apply an automatic £100 penalty. Beyond that: £10 per day from 3 months late (capped at £900), 5% of tax due at 6 months late, and another 5% at 12 months late, under Schedule 55 of the Taxes Management Act 1970. If you have a genuine reason (serious illness, bereavement, technical issue with HMRC's systems) you can appeal with evidence; HMRC accepts reasonable excuse appeals in most genuine cases.
    Do I need an accountant or can I file Self Assessment myself?+
    Legally you can file Self Assessment yourself via gov.uk for free, most simple sole-trader returns (single income source, basic expenses) are realistic to self-file. An accountant adds real value when: your trading profit is above £40,000 (extraction-strategy decisions matter), you have multiple income streams (PAYE + self-employment + property + dividends), you've crossed the £90,000 VAT threshold, you're considering incorporation, or you have an HMRC enquiry. Expect to pay £400-£1,500/year for a typical sole-trader accountant; the cost is itself a deductible expense.
    How do payments on account work?+
    When your Self Assessment tax bill exceeds £1,000 for the first time, HMRC requires payments on account toward NEXT year's tax. Half the current bill is due 31 January (alongside the current bill); the other half is due 31 July. So your first January after crossing the threshold can hit with a double-bill: last year's balance + first payment on account. Adjust via Form SA303 if you expect next year's income to drop substantially. Payments on account don't apply if more than 80% of your tax is collected via PAYE.
    Is moving crypto between my own wallets a disposal?+
    No — no change of beneficial ownership = no disposal. This is a routine HMRC position (CRYPTO22000). Keep records linking wallet addresses to your identity so you can demonstrate the same beneficial owner if HMRC enquires.
    Does the 30-day rule apply across different wallets or exchanges?+
    Yes — pooling and the s.106A 30-day rule operate at the level of the taxpayer, not the exchange. Acquisitions of the same crypto across any wallet/exchange in the 30 days following disposal are matched. Crypto tax software handles this automatically; manual computation across multiple platforms is error-prone.
    What about gas fees + transaction costs?+
    Allowable as incidental costs of acquisition or disposal (TCGA 1992 s.38 + HMRC CRYPTO22300) — added to cost on acquisition or deducted from proceeds on disposal. Gas spent on non-disposal activity (interacting with smart contracts without disposing of an asset) may be allowable depending on what the gas paid for — fact-specific.
    Do I owe CGT if I bought crypto, never sold, but the price went up?+
    No — CGT is on REALISED gains. Unrealised paper gains are not chargeable. The chargeable event is the disposal (sale, swap, gift, spend). Holding-only is non-taxable.

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