CRYPTO41150 – Cryptoassets for Business: Corporation Tax: Intangible Assets – HMRC Internal Handbook

The corporation tax rules for intangible assets (Corporation Tax Act 2009 Part 8) take precedence over other corporation tax rules, including the taxable gains rules. More information on these rules can be found in CIRD10000.

Companies that account for exchange tokens as “intangible assets” may be taxed under corporation tax rules for intangible assets if the token is both:

• an “intangible asset” for accounting purposes
• an “intangible asset” (meaning that it was created or acquired by a business for continued use. Exchange tokens that are simply owned by the business, even when held in the course of its business , will not meet this definition )

In addition, there are other specific exclusions. The list below covers some of the common exclusions, but is not intended to be an exhaustive list, these specific exclusions include:

• Financial assets
• assets held for non-commercial purposes or for mutual exchange
• land or tangible movable property rights
• other rights such as rights in companies, trusts, partnerships
• If the company does not prepare GAAP accounts, the rules apply as if GAAP accounts had been prepared.

Exchange Tokens that meet the above conditions are treated the same as other Intangible Assets.