The United Kingdom’s HM Revenue & Customs will treat certain disposals involving cryptoasset loans and liquidity pools as “no gain, no loss,” deferring Capital Gains Tax until a user makes an economic disposal of the underlying cryptocurrency.

The measure, published Monday, takes effect 6 April 2027 and applies to individuals and trustees who enter cryptoasset loan and liquidity pool arrangements, according to the policy paper. 

It amends the Taxation of Chargeable Gains Act 1992.

The rules cover three scenarios. In a single cryptoasset lending arrangement, a user who acquires or disposes of an interest in exchange for cryptoassets of the same type as those invested will be taxed on a no-gain-no-loss basis. 

Borrowing arrangements will treat borrowed cryptoassets as acquired at market value at the time of borrowing, with any collateral disregarded for Capital Gains Tax purposes.

For automated market-making arrangements — liquidity pools operated through smart contracts — a user acquiring an interest in exchange for the same type of cryptoasset is also taxed on a no-gain-no-loss basis. On exit, that treatment holds to the extent the user receives the same quantity first invested. Any difference between what was invested and what is received triggers a gain or a loss.

HMRC said the change aligns tax treatment with the economics of these arrangements, recognizing gains and losses only when a participant makes an economic disposal.

HMRC simplifies DeFi crypto tax rules

The measure addresses problems that arose from HMRC’s own 2022 guidance, which stakeholders said produced disproportionate administrative burdens. 

A call for evidence ran from July to August 2022, followed by a consultation between 27 April and 22 June 2023 that sought to align tax with economic substance by not treating crypto used in DeFi lending and liquidity pools as a taxable disposal. 

HMRC published a summary of responses at Budget 2025 and set out its approach at that time.

The change is expected to affect about 700,000 individuals who engage in these transactions, according to the paper. HMRC said users will benefit from a framework that is easier to understand.

The current UK regime treats crypto as an investment asset, with selling, swapping, or spending it counting as a disposal for Capital Gains Tax at 18% for basic-rate taxpayers and 24% for higher-rate taxpayers. The new treatment modifies that disposal rule for certain lending and liquidity pool arrangements.

Final costing will be subject to scrutiny by the Office for Budget Responsibility and set out at a future fiscal event. HMRC said the measure is not expected to have any significant macroeconomic impact.