HMRC has published a call for evidence on the 'Taxation of stablecoins', a type of cryptoasset. It seeks opinions on issues around the tax treatment of stablecoins for both individuals and companies.

Consultation
Stablecoins are currently taxed in the same manner as other Cryptoassets. The expectation is that they could play a more significant role in the economy, as they could be used for wholesale and retail payments.
The government seeks opinions from investors, professionals and firms on whether the current tax treatment of stablecoins is appropriate for the future and if changes were made, what would the potential administrative burden be.
Stablecoins are a cryptoasset that seek to maintain a stable value by:
- Referencing another asset, for example, a fiat currency such as sterling or a commodity such as gold.
- Holding a reserve of backing assets.
Stablecoins are attractive for everyday payment transactions and may be used more frequently in the future, as they:
- Benefit from blockchain technology.
- Keep the stability of traditional money.
Current tax treatment
Currently, there is no specific treatment for stablecoins, and they are taxed in the same way as other cryptoassets. The term 'stablecoin' does not yet have a specific definition in tax legislation.
The current tax treatment of stablecoins depends on the circumstances in which the coins are used and the particular features of the stablecoin in question. They are not generally considered money.
Individuals: Capital Gains Tax (CGT)
The current treatment means that stablecoins used as a form of payment will typically constitute a disposal for CGT purposes. This means transactions should be tracked and reported to HMRC. If the coins were being used for everyday transactions, this would create an administrative burden and possibly disincentivise their use.
Individuals: Income Tax
Income Tax could apply in some of the following circumstances:
- Where the individual has received stablecoins as part of their remuneration.
- Where payments for services or goods have been received.
Companies: Corporation Tax
The current treatment depends on the particular features of the stablecoin in question and how they are used. The following regimes may be relevant.
- Loan relationships.
- Intangible Fixed Assets (IFAs).
- Trading.
- Chargeable Gains.
Interest and returns
Generally, stablecoins are not considered money, so any returns generated from the lending of the coins would not be considered interest.
Options for potential reform
The government has recognised that the current tax treatment of stablecoins may create administrative burdens that do not apply where fiat currency equivalents are used.
The government is therefore seeking reform to the tax treatment of stablecoins, seeking a tax treatment that better reflects how they are used.
Individuals: CGT
- One potential solution would be to treat stablecoins as exempt assets, removing the need to treat disposals as chargeable events for CGT purposes.
- The second potential option may be to remove reporting requirements for Self Assessment purposes so that transactions below a certain value are not reportable.
Individuals: Income Tax
The government does not believe that the current Income Tax treatment is causing issues and is not considering any changes.
Companies: Corporation Tax
- One potential solution would be to bring stablecoins into the loan relationship rules (either directly into Part 5 or through Part 6 of the Corporation Tax Act).
- This would be achieved by treating them as money, or as a money debt or a loan relationship where they do not already constitute one.
- Another option is to ensure transactions are treated as transactions for the lending of money, where a company lends stablecoins.
Individuals and companies with interest-like returns
The government is considering how the returns on stablecoins should be treated and seeks opinions on this.
Responses should be emailed to
Questions
Question 1: Are there any further points of background in relation to stablecoins and the stablecoin market which would be relevant to this Call for Evidence?
Question 2: To what extent does the current CGT treatment:
- cause administrative or other difficulties for individuals, and/or
- deter the use of stablecoins, for example, in retail payments?
Question 3: Are there any difficulties caused by the current Income Tax treatment of stablecoins, and to what extent do those difficulties deter their usage?
Question 4: Currently, how do companies typically account for stablecoins in practice? Please specifically include references to USDT and USDC, 2 of the major stablecoins in the current market, as well as other common stablecoins used by companies.
Question 5: How are stablecoins typically treated in practice for Corporation Tax purposes, including where the stablecoin is itself lent or borrowed by a company?
Question 6: To what extent is it possible in practice for a stablecoin:
- to be a loan relationship, but not be accounted for as a financial asset under IFRS 9 (or equivalent) and/or
- to not be a loan relationship, but to be accounted for as a financial asset under IFRS 9 (or equivalent)?
Question 7: Are there any difficulties caused by the current Corporation Tax treatment of stablecoins, and to what extent do difficulties deter companies from using them?
Question 8: For both individuals and companies, what problems could be caused by contrasting treatment of interest-like returns generated from stablecoins and actual interest on fiat currency debt?
Question 9: Do you consider there to be any potential difficulties with the treatment of stablecoins in respect of taxes other than CGT, Income Tax and Corporation Tax?
Question 10: Does the regulatory definition of a qualifying stablecoin provide a suitable starting point for the scope of any potential tax changes?
Question 11: What would be the preferred option(s) for reforming the tax treatment of stablecoins in respect of CGT for individuals, and why?
Question 12: Should the scope of any changes to the CGT treatment be extended to include non-sterling denominated stablecoins? Why or why not?
Question 13: Are there any changes to the Income Tax treatment of stablecoins that you believe the government should be considering?
Question 14: If you consider that reform is needed for the taxation of stablecoins by companies, what would be the preferred option, and why?
Question 15: Should there be an additional accountancy-based limitation on what stablecoins are included in any reforms, or specific rules to address amounts recognised in OCI? Why or why not?
Question 16: For both individuals and companies, would it be preferable for interest-like returns to be treated in the same way as actual interest? Why or why not?
Question 17: To what extent are stablecoins used in liquidity pool arrangements? Please provide any estimates of the market share of lending and liquidity pool arrangements that involve stablecoins, including figures to support where possible.
Question 18: How should the treatment of cryptoasset loans and liquidity pools interact with the treatment of stablecoins? Would the proposed options in sections above create opportunities for tax avoidance involving lending and liquidity pools?
Useful guides on this topic
How are Bitcoin, cryptocurrencies or cryptoassets taxed in the UK?
How do you tax Bitcoin? Are cryptocurrency or cryptoasset gains or profits taxable? Can you obtain tax relief if you make losses on Bitcoin? Gains on transactions in cryptoassets are potentially taxable in the same way as other investments.
How are Cryptoassets taxed in the UK? At a glance (Freeview)
How do you tax Bitcoin? Are cryptocurrency or cryptoasset gains or profits taxable? Can you obtain tax relief if you make losses on Bitcoin?
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