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Digital Assets and Cryptocurrency: Estate Planning Tax Implications for Accountants

· 19 min

Executive Summary

HMRC's issuance of One to Many nudge letters (reference OTM000752) to agents who filed IHT returns, combined with the Cryptoasset Reporting Framework commencing 1 January 2026 under SI 2025/744, signals that cryptoasset compliance in estates is now an active enforcement priority. With 4.5 million UK adults holding cryptocurrency according to FCA Wave 6 research, accountants advising on estate administration face a distinct technical challenge: cryptoassets are property for IHT purposes under HMRC's Cryptoassets Manual and the Property (Digital Assets etc) Act 2025, yet they fall outside the loss on sale relief provisions of IHTA 1984 ss 178-189. This exclusion, coupled with the CGT death uplift under TCGA 1992 s 62 and the interaction with the residence-based IHT regime from April 2025, creates asymmetric risk profiles requiring systematic advisory engagement at both lifetime planning and estate administration stages.

1. The Enforcement Context: Why Crypto in Estates Demands Attention Now

The regulatory environment surrounding cryptoassets in UK estates has shifted from speculative concern to active enforcement. Three concurrent developments -- HMRC's targeted nudge letter campaign, the implementation of mandatory platform reporting, and statutory confirmation of crypto as personal property -- collectively signal that accountants can no longer treat digital asset identification as a peripheral estate administration task.

FCA Wave 6 research published in December 2025 estimates that 8% of UK adults -- approximately 4.5 million individuals -- hold cryptoassets, a reduction from 12% (7 million) in 2024 but with average holdings increasing in value.1 Bitcoin and Ether remain the most commonly held cryptoassets, owned by 57% and 43% of crypto holders respectively.1 The demographic concentration among men (11%) and the 18-34 age group (15%) indicates that crypto holdings will feature with increasing frequency in estate administration over coming decades, but the assets already present material compliance exposure for current estates.

HMRC has responded to perceived under-reporting through a multi-pronged enforcement strategy. The cryptoasset disclosure service, despite prompting over 100,000 nudge letters to individual holders, yielded only GBP 4 million in disclosures -- a figure widely interpreted as confirming persistent non-compliance rather than a low quantum of undeclared gains.2 More targeted correspondence has followed: HMRC's One to Many letter programme, reference OTM000752, now extends to professional agents who submitted IHT returns, reminding them of the obligation to identify and include cryptoasset holdings in estate valuations.3 The ICAEW warned in December 2025 that agents may be "overlooking IHT on cryptoassets," noting that corrections to prior returns should be submitted via form C4 quoting the OTM reference.4

The enforcement architecture becomes substantially more powerful from 2027. The Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 (SI 2025/744) came into force on 1 January 2026, implementing the OECD Crypto-Asset Reporting Framework.5 UK-based Reporting Cryptoasset Service Providers must now collect comprehensive user data -- including name, date of birth, address, tax residence, National Insurance number or UTR, and detailed transaction summaries -- with a five-year retention obligation.5 First mandatory reports to HMRC are due in 2027, providing the revenue authority with transaction-level data capable of cross-referencing against IHT returns and self-assessment filings.3

The statutory foundation for treating crypto as estate property was reinforced by the Property (Digital Assets etc) Act 2025 (c.29), which received Royal Assent on 2 December 2025.6 Section 1 provides that "a thing (including a thing that is digital or electronic in nature) is not prevented from being the object of personal property rights merely because it is neither (a) a thing in possession, nor (b) a thing in action." This creates a statutory third category of personal property, implementing the Law Commission's June 2023 recommendations on digital assets and removing any residual legal ambiguity regarding proprietary rights in cryptoassets.7

For accountants, the convergence of HMRC enforcement activity, enhanced reporting obligations, and statutory clarity establishes a professional imperative: systematic engagement with clients regarding cryptoasset holdings must become embedded in both lifetime tax planning reviews and estate administration protocols.

2. HMRC's Cryptoasset Taxonomy and IHT Treatment

2.1 Token Classification

HMRC's Cryptoassets Manual at CRYPTO10100 classifies digital assets into five categories, with tax treatment determined by the nature and use of each token rather than its nominal classification.8 Exchange tokens (such as Bitcoin and Ether) function primarily as means of payment or store of value, and are increasingly held as speculative investments. Utility tokens provide access to particular goods or services on a platform. Security tokens confer rights or interests in a business, including ownership stakes or profit-sharing arrangements. Stablecoins, designed to minimise volatility through pegging to fiat currencies or commodities, fall within the exchange token framework for tax purposes. Non-fungible tokens are separately identifiable digital assets that cannot be pooled -- each NFT requires individual treatment for both CGT and IHT purposes.9

The taxonomy has direct IHT consequences. Exchange tokens, as the most commonly held category, follow the situs and valuation rules discussed below. Security tokens may qualify for Business Property Relief under IHTA 1984 ss 103-114 where they represent interests in qualifying trading businesses -- an area where the interaction between crypto classification and BPR qualification tests warrants specialist analysis. NFTs require individual professional valuations, creating additional cost and complexity in estate administration.

2.2 IHT Status and Valuation

HMRC's position at CRYPTO25000 is unequivocal: "Cryptoassets will be property for the purposes of Inheritance Tax."10 Cryptoassets held by the deceased at death form part of the estate and must be valued at fair market value in GBP as at the date of death. This valuation presents challenges specific to digital assets: crypto markets operate continuously across global time zones with no official closing price, and price variation between exchanges can be material at any given moment.

HMRC has not published an approved methodology for determining the precise GBP value of crypto at the time of death for 24/7-traded assets. Practitioners should document the exchange rate source, the specific timestamp used, and any cross-exchange price reconciliation undertaken. Where substantial holdings are involved, a defensible valuation approach -- such as the volume-weighted average price across major exchanges at the closest recorded time to death -- reduces the risk of HMRC challenge.

Cryptoassets are declared on the IHT400 as part of the estate. Where crypto is treated as foreign-located property (see Section 5 below), form IHT417 applies. The December 2025 update to IHT417 specifically references cryptoassets as an example of foreign assets requiring disclosure.11 With the IHT nil-rate band frozen at GBP 325,000 and the RNRB at GBP 175,000 through the 2030-31 tax year (to 5 April 2031), rising crypto values increase the proportion of estates with digital asset holdings that breach the IHT threshold.12

3. The Loss on Sale Relief Gap: Crypto's Material Disadvantage

3.1 The Statutory Exclusion

Loss on sale relief under IHTA 1984 ss 178-189 provides a mechanism for reducing the IHT-chargeable value of estate assets where they are sold within a defined period after death for less than their date-of-death valuation. Section 178 defines "qualifying investments" as: shares or securities quoted on a recognised stock exchange at the date of death; holdings in authorised unit trusts; shares in open-ended investment companies; and shares in common investment funds.13 Cryptoassets do not satisfy any limb of this definition. They are not quoted on a recognised stock exchange, nor do they constitute holdings in any of the specified collective investment vehicles.

The consequence is stark. Form IHT35, used to claim loss on sale relief for quoted investments, cannot be submitted for crypto disposals.14 Executors holding crypto that depreciates significantly between the date of death and realisation bear the full IHT liability calculated on the higher death value, with no statutory mechanism for adjustment.

3.2 Worked Example: Quantifying the Exposure

Consider an estate containing 3 Bitcoin valued at GBP 200,000 at the date of death (approximately GBP 66,700 per Bitcoin). The IHT liability attributable to this holding, assuming the estate exceeds available nil-rate bands, is GBP 80,000 (GBP 200,000 at 40%). Within four months of death, Bitcoin falls 60% to approximately GBP 26,700 per unit, and the personal representatives sell the holding for GBP 80,000. The estate has realised a GBP 120,000 loss -- but no relief is available. The IHT liability remains GBP 80,000, payable from sale proceeds of the same amount, leaving zero net value from a holding that was worth GBP 200,000 at death.

By contrast, had the estate held GBP 200,000 of FTSE 100 shares that suffered an identical 60% fall and were sold within the statutory 12-month window required by IHTA 1984 s 179 for loss on sale relief, the personal representatives could claim relief to substitute the sale price as the IHT value, reducing the liability to GBP 32,000 (GBP 80,000 at 40%) -- a saving of GBP 48,000.13

This asymmetry demands proactive advisory engagement. Practitioners should model volatility scenarios for crypto holdings before advising on the timing of estate disposals, and estates with material crypto exposure should consider early realisation strategies where liquidity permits and beneficiary interests align.

3.3 The Section 171 Argument: Inaccessible Crypto on Death

IHTA 1984 s 171 provides that changes in value of the deceased's estate occurring by reason of death are treated as if they had occurred immediately before death.15 An intellectually compelling -- but entirely untested -- argument arises where crypto becomes permanently inaccessible on death because private keys were known only to the deceased and are not recoverable.

The reasoning proceeds as follows: if the deceased held crypto in a self-custodied wallet with no succession planning for private key access, the death itself causes the asset to become permanently irretrievable. This change in value -- from the full market value to effectively nil -- is "caused by death" within the meaning of s 171, and should therefore reduce the estate value accordingly.

HMRC has not published guidance on this specific application of s 171 to cryptoassets.10 No First-tier Tribunal or Upper Tribunal decision has addressed the question. Professional opinion remains divided: some practitioners view the argument as consistent with the statutory purpose of s 171 (which was designed to address assets such as partnership interests that diminish in value on the holder's death), while others contend that the crypto remains extant on the distributed ledger regardless of key loss, and the inability to access it is a practical constraint rather than a change in value.

Accountants encountering estates with inaccessible crypto should present s 171 as a potential argument warranting referral to specialist tax counsel, not as an established position on which to base IHT return filing. HMRC's position, informed by CRYPTO22400 which confirms that losing private keys is not a disposal for CGT purposes (since the tokens continue to exist on the ledger), suggests the revenue authority would resist the contention that lost keys eliminate IHT value.16

4. CGT on Death and Estate Administration: The Death Uplift and Its Interactions

4.1 Base Cost Uplift on Death

TCGA 1992 s 62 provides that on death, assets are deemed to be acquired by the personal representatives at their market value, with no CGT charge arising on the deemed disposal.17 This provision applies to cryptoassets without restriction: all unrealised gains accumulated by the deceased during their lifetime are eliminated, and the personal representatives (and subsequently the beneficiaries) acquire a base cost equal to the date-of-death market value.

The planning tension is significant. Retaining crypto until death achieves a full CGT wash -- potentially eliminating substantial gains at 24% (higher rate) or 18% (basic rate) for 2025-26.18 However, this strategy simultaneously maximises IHT exposure on the full death value, compounded by the absence of loss on sale relief should the market decline post-death.

4.2 Spousal and Civil Partner Transfer Planning

Transfers of cryptoassets between spouses or civil partners during lifetime are treated as "no gain, no loss" disposals under TCGA 1992 s 58, with the recipient acquiring at the transferor's original base cost.19 This creates a practical planning opportunity: reorganising crypto holdings between spouses enables each partner to utilise the GBP 3,000 annual CGT exempt amount when making subsequent disposals, and positions holdings for potential IHT-exempt spousal transfers on death under IHTA 1984 s 18.18

Accountants should note that these transfers extend to crypto held across different wallet types and exchange accounts. A transfer between a husband's exchange account and wife's self-custodied hardware wallet remains a no gain/no loss disposal provided the beneficial ownership genuinely transfers.

4.3 Lifetime Gifting: The Risk of Asymmetric Outcomes

The interaction between CGT and IHT on lifetime gifts of crypto creates what practitioners may recognise as a compounded risk scenario. A gift of appreciated crypto to a non-exempt beneficiary triggers CGT at the market value on the date of gift (a deemed disposal at market value under TCGA 1992 s 17). If the donor survives seven years, the gift falls out of the IHT estate as an exempt potentially exempt transfer. If the donor dies within seven years, the gift re-enters the IHT estate at the date-of-gift value (with taper relief available after three years) -- but the CGT death uplift under s 62 is lost because the asset was disposed of during lifetime.

The result can be a "triple burden": CGT paid on the gift, IHT payable on the failed PET, and no death uplift to offset either charge. Practitioners advising on lifetime transfers of crypto should model the combined CGT and IHT outcomes across survival scenarios before recommending disposition strategies.

4.4 Pooling Rules and Record-Keeping Obligations

Personal representatives administering crypto estates must reconstruct the deceased's cost history to calculate the section 104 pool for each fungible token type.20 The same-day rule (matching disposals to same-day acquisitions first) and the 30-day rule (matching disposals to acquisitions within the following 30 days) apply, with the balance drawn from the section 104 pool at the weighted average cost.20

HMRC's record-keeping requirements at CRYPTO10400 place the onus on the individual to maintain records of each transaction: token type, date, buy or sell, units, GBP value, and cumulative holdings.21 Exchange platforms may not retain records indefinitely, and decentralised exchange transactions generate no centralised record. Practitioners should advise clients proactively on lifetime record-keeping and, at estate administration, pursue data from all platforms where the deceased may have traded.

5. Situs, the Residence-Based Regime, and Cross-Border Crypto Holdings

5.1 The HMRC Situs Rule for Exchange Tokens

HMRC's position at CRYPTO22600 is that the location of exchange tokens is determined by the beneficial owner's residence.22 For a UK-resident holder, exchange tokens are UK-situs property regardless of where the exchange platform is incorporated, where the blockchain nodes are physically located, or which jurisdiction's regulatory framework governs the exchange. Non-UK-resident holders' exchange tokens are located in their jurisdiction of residence. Where tokens represent an underlying asset (such as tokenised real estate or fractional equity), situs follows the underlying asset's location rather than the token holder's residence.22

5.2 Interaction with the Long-Term UK Resident Test

The residence-based IHT regime enacted from 6 April 2025 under Finance Act 2025 (c.8) Part 2 Chapter 4 replaced the domicile-based system for determining the scope of IHT on worldwide assets.23 An individual is a long-term UK resident if resident in the UK for at least 10 of the previous 20 tax years. Long-term UK residents are liable to IHT on their worldwide estates, including crypto held on overseas platforms. Non-long-term UK residents are liable only on UK-situs assets.

For UK-resident crypto holders, the practical impact is limited: exchange tokens are already UK-situs under CRYPTO22600, so the shift from domicile to residence does not change the IHT position on crypto. The regime principally affects two scenarios. First, internationally mobile individuals who depart the UK retain an IHT "tail" of 3 to 10 years depending on the length of their UK residence, during which their worldwide crypto holdings remain within IHT scope.23 Second, non-UK-domiciled individuals who are long-term UK residents now face IHT on worldwide crypto holdings -- a significant expansion for those who previously relied on non-domiciled status to exclude overseas crypto from the UK IHT net.

Practitioners advising clients with cross-border crypto holdings should map each holding against the situs rules, the long-term UK resident test, and any applicable double taxation treaty provisions. HMRC does not currently treat exchange tokens as "situated" by reference to blockchain geography, but the interaction of tokenised assets with underlying asset situs requires case-by-case analysis.22

6. DeFi, Staking, and Estate Complexity

Decentralised finance positions introduce additional layers of estate administration complexity. HMRC's Cryptoassets Manual at CRYPTO60000 addresses DeFi transactions, confirming that transactions involving a change of beneficial ownership constitute disposals for CGT purposes.24 Staking rewards are generally treated as miscellaneous income subject to income tax, while yield farming generates new tokens that may be classified as income or capital depending on the specific mechanism.24

The HMRC consultation on DeFi taxation proposed a "no gain, no loss" framework for DeFi lending and staking transactions. The government published a summary of responses in November 2025, indicating it would continue to assess the merits of the NGNL approach for single-token arrangements, crypto borrowing, and automated market makers, but no draft legislation has been published.25 This legislative vacuum creates material uncertainty for estates holding DeFi positions: liquidity pool tokens, staking contracts, and yield farming arrangements may be subject to smart contract lock-up periods that prevent immediate realisation, and protocol risk (including the possibility of platform failure) complicates valuation.

Executors face identification challenges that are qualitatively different from traditional assets. DeFi positions do not appear on centralised exchange platforms and require direct blockchain interrogation to discover. Staking rewards and farming yields that accrue post-death generate income tax liabilities for the personal representatives, adding to the administrative burden. Practitioners advising living clients should recommend explicit documentation of all DeFi participation, including protocol names, wallet addresses, and position details, as part of a comprehensive digital asset succession plan.

7. Pension Interaction: SIPP-Held Crypto and April 2027

The inclusion of unused pension funds in the IHT estate from 6 April 2027 introduces a further dimension for estates with crypto exposure.26 Some self-invested personal pension schemes permit direct or indirect investment in cryptoassets, meaning that crypto may form part of the pension fund value brought within the IHT net from April 2027. This creates a potential dual exposure: direct crypto holdings valued and charged to IHT under the existing framework, and SIPP-held crypto valued as part of the pension fund subject to the new pension IHT rules.

Planning considerations include reviewing the pension crypto allocation in the context of the overall estate IHT position and sequencing pension drawdown to reduce the combined IHT liability. However, accountants should note the FCA perimeter: decisions regarding pension investment strategy, including whether to retain or dispose of crypto within a SIPP, constitute regulated financial advice and fall outside the scope of tax advisory services. The accountant's role is to quantify the IHT exposure and recommend that clients seek regulated advice on pension allocation decisions where crypto holdings are material.26

Conclusion: Building the Crypto Estate Planning Framework

The tax treatment of cryptoassets in UK estates demands a structured advisory response from accountants. The convergence of HMRC enforcement activity (OTM000752 nudge letters, CARF platform reporting from 2027), statutory confirmation of crypto as personal property (Property (Digital Assets etc) Act 2025), and the absence of loss on sale relief creates a compliance and planning landscape materially different from traditional investment assets.

Practitioners should embed the following framework into estate administration and lifetime planning workflows. At client onboarding and annual review, systematic questioning about cryptoasset holdings -- including exchange accounts, self-custodied wallets, DeFi positions, and SIPP-held crypto -- should become standard practice. For lifetime planning, modelling the CGT versus IHT trade-offs specific to crypto (the death uplift benefit against the loss on sale gap) enables informed client decisions. Spousal transfer planning under TCGA 1992 s 58 offers an accessible CGT efficiency that many practitioners overlook for digital assets.

At estate administration, a structured identification protocol is essential: requesting exchange records, interrogating hardware wallet contents, reviewing blockchain transactions, and checking for DeFi positions that may not appear on conventional statements. Valuation documentation should record the methodology, timestamp, and exchange rate sources used. The section 171 argument for inaccessible crypto remains an open question warranting specialist referral rather than routine application.

Cross-referral points should be clearly defined. Solicitors should draft wills with specific crypto provisions addressing private key succession. Regulated financial advisors should address pension crypto allocation decisions. Specialist crypto-tax advisors may be required for complex DeFi positions or cross-border situs analysis under the residence-based regime. The accountant's role sits at the centre of this advisory network, providing the tax quantification and compliance framework on which effective crypto estate planning depends.

CPD Declaration

Estimated Reading Time: 20 minutes Technical Level: Advanced Practice Areas: Inheritance Tax, Capital Gains Tax, Estate Administration, Cryptoasset Compliance

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the HMRC classification of cryptoassets and their treatment as property for IHT purposes under CRYPTO25000 and the Property (Digital Assets etc) Act 2025 (c.29)
  2. Evaluate the impact of the loss on sale relief exclusion under IHTA 1984 ss 178-189 on estates containing volatile cryptoasset holdings, including quantification of the asymmetric risk
  3. Apply the CGT death uplift under TCGA 1992 s 62 and spousal transfer rules under TCGA 1992 s 58 to crypto estate planning scenarios
  4. Analyse the interaction between CARF reporting obligations under SI 2025/744 and IHT compliance risk for estates with cryptoasset holdings

ICAEW/ACCA Competency Mapping

  • Tax compliance and planning: application of IHT and CGT rules to non-traditional asset classes
  • Professional ethics and client engagement: identifying undisclosed cryptoasset holdings in estate administration

Reflective Questions

  1. How would the integration of systematic cryptocurrency identification into estate administration workflows improve IHT compliance outcomes within the practice?
  2. What documentation protocols should be recommended to clients holding cryptoassets to mitigate the loss on sale relief gap and private key access risk on death?
  3. How might CARF transaction data, available from 2027, change the approach to reviewing prior IHT returns for clients known to have held cryptoassets?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 24 February 2026. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. FCA: Cryptoassets consumer research 2025 (Wave 6, December 2025). https://www.fca.org.uk/publications/research-notes/cryptoassets-consumer-research-2025 ↩ ↩2

  2. AccountingWEB: HMRC's cryptoasset disclosure nets just GBP 4m (October 2025). https://www.accountingweb.co.uk/tax/hmrc-policy/hmrcs-cryptoasset-disclosure-nets-just-ps4m ↩

  3. Addleshaw Goddard: HMRC issue one to many letters prompting inheritance tax (IHT) compliance (January 2026). https://www.addleshawgoddard.com/en/insights/insights-briefings/2026/tax-and-structuring/hmrc-issue-one-to-many-letters-inheritance-tax-iht-compliance/ ↩ ↩2

  4. ICAEW: Agents may be overlooking IHT on cryptoassets (December 2025). https://www.icaew.com/insights/tax-news/2025/dec-2025/agents-may-be-overlooking-iht-on-cryptoassets ↩

  5. The Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 (SI 2025/744). https://www.legislation.gov.uk/uksi/2025/744/contents/made ↩ ↩2

  6. Property (Digital Assets etc) Act 2025 c.29. https://www.legislation.gov.uk/ukpga/2025/29/enacted ↩

  7. Law Commission: Digital assets project (June 2023). https://lawcom.gov.uk/project/digital-assets/ ↩

  8. HMRC CRYPTO10100 -- Introduction to cryptoassets: what are cryptoassets. https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto10100 ↩

  9. HMRC CRYPTO22100 -- Cryptoassets for individuals: Capital Gains Tax: what is a disposal. https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto22100 ↩

  10. HMRC CRYPTO25000 -- Cryptoassets for individuals: Inheritance Tax. https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto25000 ↩ ↩2

  11. GOV.UK: Inheritance Tax: foreign assets (IHT417, updated December 2025). https://www.gov.uk/government/publications/inheritance-tax-foreign-assets-iht417 ↩

  12. GOV.UK: Inheritance Tax thresholds. https://www.gov.uk/government/publications/inheritance-tax-thresholds/inheritance-tax-thresholds ↩

  13. Inheritance Tax Act 1984, Section 178 (Preliminary -- qualifying investments). https://www.legislation.gov.uk/ukpga/1984/51/section/178 ↩ ↩2

  14. GOV.UK: Inheritance Tax: claim for relief -- loss on sale of shares (IHT35). https://www.gov.uk/government/publications/inheritance-tax-claim-for-relief-loss-on-sale-of-shares-iht35 ↩

  15. Inheritance Tax Act 1984, Section 171 (Changes occurring on death). https://www.legislation.gov.uk/ukpga/1984/51/section/171 ↩

  16. HMRC CRYPTO22400 -- Cryptoassets for individuals: Capital Gains Tax: losing private keys. https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto22400 ↩

  17. Taxation of Chargeable Gains Act 1992, Section 62 (Death: general provisions). https://www.legislation.gov.uk/ukpga/1992/12/section/62 ↩

  18. GOV.UK: Capital Gains Tax rates and allowances. https://www.gov.uk/guidance/capital-gains-tax-rates-and-allowances ↩ ↩2

  19. Taxation of Chargeable Gains Act 1992, Section 58 (Husband and wife). https://www.legislation.gov.uk/ukpga/1992/12/section/58 ↩

  20. HMRC CRYPTO22200 -- Cryptoassets for individuals: Capital Gains Tax: pooling. https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto22200 ↩ ↩2

  21. HMRC CRYPTO10400 -- Introduction to cryptoassets: record keeping. https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto10400 ↩

  22. HMRC CRYPTO22600 -- Cryptoassets for individuals: Capital Gains Tax: determining the location of exchange tokens. https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto22600 ↩ ↩2 ↩3

  23. Finance Act 2025 c.8 Part 2 Chapter 4 (Inheritance Tax: Long-term UK resident). https://www.legislation.gov.uk/ukpga/2025/8/part/2/chapter/4 ↩ ↩2

  24. HMRC CRYPTO60000 -- Decentralised Finance: contents. https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto60000 ↩ ↩2

  25. GOV.UK: The taxation of decentralised finance (DeFi) -- summary of responses (2023). https://www.gov.uk/government/consultations/the-taxation-of-decentralised-finance-involving-the-lending-and-staking-of-cryptoassets/outcome/the-taxation-of-decentralised-finance-defi-involving-the-lending-and-staking-of-cryptoassets-summary-of-responses ↩

  26. GOV.UK: Inheritance Tax -- unused pension funds and death benefits. https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩ ↩2

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