Executive Summary
- The Argentine platform should build the hypothetical crypto payroll service around unconditional payment of net GBP wages into each employee's own bank account. A separate, voluntary purchase can follow that credit. A net-pay calculation or transfer to the employer's conversion contractor does not itself establish payment of the employee's wage entitlement. (Employment Rights Act 1996, ss. 13 and 27.)
- Direct token remuneration and an additional token benefit require separate employment and tax analysis. Benefits in kind do not count towards minimum wage, while transferable tokens can constitute taxable earnings subject to PAYE and Class 1 National Insurance. Employee agreement cannot waive the statutory pay floor. (National Minimum Wage Act 1998, ss. 1 and 49; National Minimum Wage Regulations 2015, reg. 10(f); Income Tax (Earnings and Pensions) Act 2003, ss. 62, 696 and 702.)
- A failed conversion before the agreed salary payment leaves the employer's wage obligation outstanding. Failure after a genuine, independent purchase normally engages the employee's rights against the conversion provider. A depeg requires a further distinction between a promise of GBP value and a promise of token units, with ownership and delivery recorded separately. (Employment Rights Act 1996, ss. 13, 24 and 27(5); Consumer Rights Act 2015, ss. 49, 57 and 62.)
- UK permissions attach to the actual payment, exchange, custody and communication functions. An AML registration does not confer payment-service authority, and EU authorisation does not provide a UK passport. The substantive UK crypto authorisation regime begins on 25 October 2027; its preparatory application process does not replace today's requirements. (Payment Services Regulations 2017, regs. 2 and 138; Money Laundering Regulations 2017, regs. 8, 14A and 56; Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, reg. 1.)
- Argentina's securities regulator, the CNV, requires a separate permission decision under RG 1172. Its referral provision excludes receiving, transmitting or executing orders. A company that retains the client's conversion and transfer service must assess registration for those functions, even when a foreign provider performs execution. (Law 25,246, art. 4 bis; CNV Normas, Title XIV, Chapter III, arts. 1, 9, 35 and 36, as substituted by RG 1172/2026.)
- The platform should collect its separately invoiced service fees without receiving wage or purchase principal. Argentine service-export receipts, AML duties and asset-platform reporting have distinct triggers; a software description cannot displace an obligation arising from actual functions. (BCRA, Exterior y cambios, §2.2; UIF Resolution 49/2024, arts. 3 and 16; AFIP RG 4614/2019, arts. 3, 5 and 6, as amended by ARCA RG 5804/2025.)
- Employee communications and payroll data need their own controls. Persuasive promotion of a qualifying cryptoasset requires a lawful UK communication route. Argentina's UK adequacy status permits the relevant international data transfer, while processor contracts, security and purpose limits continue to apply. (Financial Services and Markets Act 2000, s. 21; Financial Promotion Order 2005, art. 73ZA; UK GDPR, arts. 5, 28, 32 and 44A; Data Protection Act 2018, Sch. 21, paras. 4–5.)
Salary payment before the employee's purchase
The employer should remain responsible for paying the full contractual GBP salary through ordinary payroll. The proposed stablecoin feature would then operate under the employee's separate purchase contract. This changes the original proposal: the Argentine company would not receive an employer instruction to discharge wages through conversion.
The employer first calculates gross pay, lawful deductions and the net amount due. Employee PAYE and employee National Insurance reduce the amount paid to the employee. Employer National Insurance remains an additional employer liability and generally cannot be recovered from the worker. The employer must also meet its obligations to HMRC, regardless of any provider's role in calculations or remittance. (Income Tax (Earnings and Pensions) Act 2003 (ITEPA), s. 710; Income Tax (Pay As You Earn) Regulations 2003, regs. 21 and 62; Social Security Contributions and Benefits Act 1992 (SSCBA), Sch. 1, paras. 3 and 3A.)
For this product, the employment terms should make full, settled and unconditional GBP credit to the employee's nominated bank account the payment condition. The employee must be able to keep or spend that money. The employer remains the wage debtor until that condition is met; its payment to its own contractor is only a step towards performance. The credited balance must be held in the employee's own account under that account's terms. A payroll status marked 'paid' is inadequate evidence without the corresponding settlement and reconciliation records. (Employment Rights Act 1996 (ERA), ss. 8, 13(3) and 27(1).)
Only after that credit should the employee fund the separately identified conversion provider. The employee becomes that provider's customer and creditor for the agreed execution, token delivery or refund. A standing instruction can automate the purchase if it depends on actual receipt and remains revocable for future transactions. The employer must have no power to reclaim the credited wages or compel conversion.
An employee can appoint an agent to receive payment, so personal bank credit is not the only legally conceivable discharge mechanism. The selected condition removes an avoidable dispute over whether a platform received money for the employer or the employee. A design that relies on receipt agency would require that authority and the resulting ownership to be established, with a separate minimum-wage and deduction analysis. Agreement to a new label cannot extinguish an unpaid GBP entitlement. (ERA, ss. 13(1)–(6) and 27.)
Token remuneration and minimum-wage pay
Direct token remuneration can be considered above otherwise compliant monetary pay, but employee consent alone cannot make it lawful. The contract must identify whether the employer owes a GBP amount to be settled in tokens, a fixed token quantity, or separate components. Any change to existing pay requires effective agreement and the required written particulars. Deducting money wages also requires a statutory basis, an applicable contractual provision or qualifying prior written consent. (ERA, ss. 1(4), 4 and 13.)
The employer must calculate minimum-wage pay independently of taxable earnings and take-home pay. Benefits in kind have no value in that calculation, apart from the separate accommodation provisions. An exchange-token allocation treated as a benefit in kind therefore cannot fill a monetary shortfall, even when it can readily be sold. The employer must satisfy the applicable hourly rate for the correct hours and pay-reference period using remuneration that counts under the rules. (National Minimum Wage Act 1998, ss. 1 and 49; National Minimum Wage Regulations 2015 (NMW Regulations), regs. 6–13, especially reg. 10(f).)
The separate-purchase design preserves monetary salary because the employee buys tokens with money already received. Its independence must extend to charges. Worker payments can reduce minimum-wage pay where they benefit the employer or meet employment-connected expenditure, including payments made after receipt of wages. A compulsory purchase, an employer rebate from employee fees, or a charge for access to ordinary pay would require a fresh calculation. The recommended design charges the employer for payroll administration and leaves employees free to retain all their net GBP. (NMW Regulations, regs. 12–13; HMRC, NMWM11020 and NMWM11030, administrative guidance.)
For direct token remuneration, the employer remains responsible for the promised payment while its contractor obtains and transfers the asset. Funding the contractor does not itself establish employee ownership. If monetary wages are underpaid, ERA sections 13 and 24 provide the relevant deduction remedy. Section 27(5) generally excludes the monetary value of benefits in kind from Part II wages, subject to its voucher exception. An unfulfilled promise of token units may therefore require contractual enforcement instead of the same statutory wage claim.
PAYE and National Insurance on token remuneration
A transferable token received by reason of employment can constitute earnings because it has money's worth. A liquid stablecoin will commonly also satisfy the readily convertible asset rules, which bring non-cash remuneration into payroll withholding. The statutory test concerns trading arrangements and convertibility; the word 'stablecoin' does not determine the result. HMRC's published position generally treats exchange tokens as readily convertible assets. (ITEPA, ss. 62(2)–(3), 696 and 702; HMRC, CRYPTO42050 and CRYPTO42100, administrative guidance.)
For an asset within that test, the employer must account for PAYE on a reasonable estimate of its GBP value. Class 1 National Insurance ordinarily applies under the corresponding earnings and asset rules. Payroll needs the asset and chain identity, quantity, valuation time, executable market price, currency conversion and relevant charges. A dollar peg cannot establish the GBP value without that evidence. (ITEPA, s. 696; SSCBA, ss. 3 and 6; Social Security (Contributions) Regulations 2001, Sch. 2, para. 5 and Sch. 3, Parts II–III.)
Salary entitlement, tax receipt and delivery to an external wallet can occur at different times. Money earnings are generally received at the earlier of payment and entitlement, with additional rules for directors. Non-money earnings are generally received when the benefit is provided. An employee who acquires beneficial ownership through a custodian may receive the asset before withdrawing it to a personal wallet. Payroll should therefore record entitlement, custody allocation and external delivery separately. (ITEPA, ss. 18 and 19(4); HMRC, EIM11956, administrative guidance.)
The employer should retain enough monetary remuneration to make lawful employee deductions, or establish another lawful collection arrangement. If the cash available cannot support full PAYE deductions on a notional payment, the employer still accounts for the tax. Income tax not made good within the statutory period can itself become earnings: section 222 uses 90 days after the relevant tax year's end. Employer National Insurance must remain separately funded. (ITEPA, ss. 222 and 710; PAYE Regulations 2003, reg. 62; SSCBA, Sch. 1, para. 3A.)
Real Time Information reporting ordinarily occurs on or before payment. The notional-payment exception permits reporting as soon as reasonably practicable, within 14 days after tax-month end, where on-time reporting cannot be achieved. Corrections must follow the applicable reporting procedure. Outsourcing payroll preparation leaves these duties with the employer. (PAYE Regulations 2003, regs. 67B, 67C and 67E.)
An additional benefit and the employee's later tax position
A genuinely additional token award can be kept separate from the ordinary GBP wage obligation. The employer must define its own promise: token units or GBP value, vesting or eligibility conditions, tax funding, ownership and delivery. Ordinary salary can then be discharged while an outstanding award remains enforceable on its terms. Relabelling an accrued salary debt as a bonus would not achieve that separation. (ERA, ss. 13 and 27(5); ITEPA, ss. 18, 19 and 62.)
An additional award of transferable tokens remains subject to the earnings analysis. Its position above salary does not automatically make it a P11D benefit with Class 1A National Insurance. Readily convertible tokens normally follow the PAYE and Class 1 treatment described above. Where the asset does not meet that test, the reporting and contribution analysis changes; HMRC's non-readily-convertible exchange-token guidance addresses employee Self Assessment and employer Class 1A. The employer must settle the asset's classification before granting the award. (ITEPA, ss. 62, 64, 696 and 702; SSCBA, s. 10; HMRC, CRYPTO42250, administrative guidance.)
Salary sacrifice and cash alternatives add another distinction. Optional remuneration arrangements require the relevant statutory valuation rules; for residual benefits, section 203A compares cost with remuneration foregone. Where both rules apply, section 64 retains the earnings charge and adds any excess required by the benefits code. Employer-paid conversion fees or token top-ups also require their own tax and reporting assessment. The recommended purchase therefore uses the employee's own money without an employer subsidy. (ITEPA, ss. 62, 64, 69A–69B and 201–204.)
After GBP wages have genuinely been paid and taxed, a market-price purchase with the employee's net funds does not create a second salary payment. Later sale, exchange or spending can produce a chargeable gain or allowable loss under the applicable computation. The employee should retain GBP acquisition costs and disposal records. A later depeg does not automatically reverse employment income already received. (Taxation of Chargeable Gains Act 1992, ss. 21 and 37–38.)
The government's proposed stablecoin capital-gains exemption has prospective April 2027 dates and remains draft legislation. It supplies no present exemption for later stablecoin disposals and does not remove employment PAYE or National Insurance. Product terms should describe the employee's current recordkeeping obligations without promising a tax saving. (HMRC, Tax treatment of stablecoins, draft legislation published 13 July 2026, cl. 1.)
Failed conversion and loss of the peg
The employer should pay outstanding GBP wages when conversion fails before the selected bank-credit condition. A provider indemnity can reimburse the employer, but cannot substitute for payment to the employee. Where the employer has underpaid money wages, the tribunal can order payment and compensation for attributable financial loss within the statutory remedy. (ERA, ss. 13 and 24.)
For direct token remuneration, failure must be tested against the actual promise. If the employer owes a GBP value at delivery, a pre-delivery depeg or adverse execution price does not satisfy that value obligation. A valid promise of a fixed token quantity above compliant monetary pay creates a different exposure. The employer must deliver the promised units under the agreed terms; the peg alone supplies no contractual GBP guarantee. A separately promised bonus follows its award terms while ordinary wages remain payable independently. (ERA, ss. 13 and 27(5); ITEPA, ss. 18–19.)
For the recommended purchase after salary receipt, the provider should owe execution within the agreed price and timing limits, or a refund under the failed-order terms. A market loss after the employee acquires ownership ordinarily falls within the investment exposure accepted under that contract. If the provider misses a deadline, exceeds a slippage limit or sends tokens to the wrong address, its own breach requires separate treatment. Where the employee contracts as a consumer, reasonable care and skill and the restrictions on exclusion clauses continue to apply. (Consumer Rights Act 2015, ss. 49, 57 and 62.)
An employee-supplied wrong address differs from a provider entering or substituting the wrong address. The terms should allocate those events separately, with supported-chain checks, address confirmation, an instruction audit trail and a procedure for attempted recovery. An irreversible blockchain transfer does not itself determine contractual liability. Nor does a transaction hash prove that the employee owned the tokens, received the promised value or had already been paid wages.
Provider insolvency requires the actual holding arrangement to be examined. Relevant payment or e-money funds can attract statutory safeguarding, with FCA CASS 15 supplementing the regime from 7 May 2026. That protection does not extend automatically to every balance held by the same group or to purchased tokens. The employee terms should identify the contracting entity, custodian, account arrangement, ownership rights and applicable compensation or complaint protection without describing tokens as insured deposits. (Payment Services Regulations 2017, reg. 23; Electronic Money Regulations 2011, reg. 20; FCA Handbook, CASS 15; Money Laundering Regulations 2017, reg. 60A.)
UK permissions for each payment and token function
The product needs an entity-specific permission map before the first employee order. The employer pays wages; a bank or permitted payment provider executes the monetary transfer; the conversion provider receives the employee's purchase instruction and supplies the tokens. Any custodian or transfer provider must be named separately where another entity performs that role. Group branding and a partner agreement cannot establish each entity's permission.
Receiving and forwarding GBP can constitute money remittance or another payment service. Initiating a payment from the employee's bank account can also be regulated without custody. The technical-service exclusion requires that the supplier never possess the funds and excludes payment initiation and account information services. A platform's software description therefore cannot establish the exclusion while it independently initiates the customer's payment. Genuine outsourced technical work under a payment provider's responsibility requires its own contractual and functional analysis. (Payment Services Regulations 2017 (PSRs), regs. 2, 25(1)–(3) and 138, Sch. 1, Part 1 and Part 2, para. 2(j).)
Token exchange and custody require a separate test under the Money Laundering Regulations 2017 (MLRs). The exchange definition expressly includes arranging or making arrangements with a view to exchange. Holding private keys or safeguarding cryptoassets can bring the custody definition into play. A firm conducting the relevant UK business must register before operating, even where another firm executes its transactions. That registration addresses AML obligations and does not supply payment-service authority. (MLRs, regs. 8–9, 14A and 56.)
The token's rights must also be classified. A claim on an issuer, issuance on receipt of funds and acceptance by others can engage the electronic-money definition. Securities or other specified investments require the relevant Financial Services and Markets Act analysis. A reference to a fiat currency alone establishes neither classification. The selected issuer, redemption rights and operational arrangements must therefore match the permissions relied on. (Electronic Money Regulations 2011, reg. 2; Financial Services and Markets Act 2000 (FSMA), ss. 19 and 22.)
Territorial reach differs between these tests. UK customers alone do not invariably establish current UK MLR business. FCA payment guidance also recognises that a provider incorporated, located and operating wholly overseas may serve UK customers online without providing a payment service in the UK. UK establishment, staff, agents and actual operations remain material. The recommended launch should use entities with documented UK rights for the selected activities, instead of relying on an unexplained overseas exemption. (MLRs, regs. 8–9; PSRs, reg. 138; FCA Handbook, PERG 15.6, Q46, guidance.)
An EU execution partner and the incoming UK regime
An EU provider can be considered only for the services and territories its permissions cover. Authorisation under the EU Markets in Crypto-Assets Regulation (MiCA) is service-specific, and its cross-border rights operate within the Union. It does not create UK access. MiCA also requires payment services connected with crypto services to be supplied by an appropriately authorised provider, whether that is the crypto firm or a third party. (Regulation (EU) 2023/1114, arts. 59(1), (6)–(7), 65 and 70(4).)
For an e-money token, transfer and custody arrangements can require payment-service analysis alongside MiCA. The EBA's February 2026 opinion addresses that overlap and the end of earlier supervisory transition. Its limited treatment of pending payment-authorisation applications does not provide a general route to acquire new customers. An employer should require evidence of the actual authorised entity or permitted partnership for this flow, including the applicable Member State's implementation. (EBA Opinion EBA/OP/2026/01, paras. 8–15, nonbinding supervisory opinion.)
The UK has enacted a further crypto authorisation regime with substantive commencement on 25 October 2027. The 2026 regulations introduce activities covering custody, dealing and arranging, with territorial provisions relevant to overseas firms serving UK consumers. Earlier commencement for preparatory purposes does not activate the ordinary operating regime or its exemptions ahead of that date. (Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102), regs. 1, 40 and 41(6).)
The FCA has specified an application period from 30 September 2026 to 28 February 2027. Existing AML registration does not automatically grant the incoming permission, and transitional arrangements depend on their statutory conditions. The commercial agreements should require the provider to obtain the relevant future permission, disclose application or permission failures, and support migration or suspension before continued service becomes unlawful. (SI 2026/102, regs. 52–60; FCA direction under reg. 52, dated 20 February 2026, §§2–3.)
Employee communications and purchase controls
An employer can create a financial promotion through its benefits portal or employee email. FSMA section 21 restricts invitations or inducements to engage in investment activity made in the course of business. It also covers an overseas communication capable of having an effect in the UK. FCA guidance distinguishes neutral employee information from communications intended to persuade employees to invest. Describing tokens as a safer salary account or encouraging an allocation can therefore change the legal treatment of the communication. (FSMA, s. 21(1)–(3); FCA Handbook, PERG 8.4.34G.)
The crypto-specific rules depend on the token's classification. The qualifying-cryptoasset definition requires fungibility and transferability and excludes electronic money and specified other controlled investments. Those assets require their own promotion analysis. (Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (FPO), Sch. 1, para. 26F(1)–(4).)
The communication needs a lawful route: communication by an authorised person, qualifying approval by an authorised approver, or an applicable exemption. The crypto-specific route in article 73ZA also permits a registered crypto firm's own qualifying communication. Its on-behalf route requires a non-real-time communication prepared by the registered firm. An employer cannot treat the firm's review of employer-written promotional copy as equivalent to that condition. A payment institution or electronic money institution is not, solely through that status, an FSMA-authorised approver. (FSMA, ss. 21 and 55NA; FPO, art. 73ZA.)
The applicable FCA rules govern risk warnings and the retail purchase process. The first direct-offer promotion ordinarily requires a 24-hour wait from the customer's request, with personalised warnings and categorisation in the prescribed sequence. Processing a responsive order requires a positive appropriateness assessment, subject to the specified exception for a previous assessment. A recurring purchase does not require the initial waiting period to restart every month. Employer rewards conditional on investing must also be tested against the restriction on incentives. (FCA Handbook, COBS 4.12A.7R–9G, 4.12A.10R–11R, 4.12A.15R(1)–(3), 4.12A.18R, 4.12A.20R–21R and 4.12A.28R(1)–(2).)
Licentium's UK crypto marketing analysis develops the communication controls. Atlas offers preliminary screening of proposed content against marketing rules. Its screening does not supply FSMA section 21 approval; the employer and provider still need the applicable communication route and accountable review.
The provider must also complete its applicable AML checks and transfer-information duties before releasing tokens. UK Travel Rule requirements distinguish transfers involving another crypto business from unhosted wallets. For an unhosted wallet, information requests depend on the statutory risk assessment; wallet ownership proof is not an unconditional requirement for every transfer. Missing required information can prevent release. The purchase terms should explain those holds without allowing them to delay the employer's independent GBP payroll. (MLRs, regs. 64C(1), (4)–(9) and 64G(1)–(4).)
Argentina's registration and referral boundaries
The Argentine company must decide whether it will provide the conversion and transfer service or genuinely limit its functions. Registration as a virtual-asset service provider (PSAV) applies to an Argentine-incorporated provider carrying on a listed activity as a business for another person. Serving only UK employees does not turn it into a foreign provider eligible for the separate territorial tests. The natural-person volume exception does not exempt this company. (Law 25,246, art. 4 bis; CNV Normas (N.T. 2013), Title XIV, Chapter III, arts. 1–4, as substituted by RG 1172/2026.)
If the company undertakes fiat-to-token conversion and transfer for the employee, Categories 1 and 3 are the principal candidates. Custody, administration or control instruments can add Category 4. Argentine law does not reproduce the UK's broad exchange-arranging definition, so every automated message between providers cannot automatically be classified as exchange. The company's contractual undertaking, customer relationship and actual powers determine whether it performs a listed service. (Law 25,246, art. 4 bis; CNV Chapter III, art. 9.)
The narrower referral route imposes a concrete limit. Article 35 excludes intervention in the receipt, transmission or execution of orders. It concerns referral to an identified registered PSAV, with a written agreement and the prescribed five-day notification. It does not create a general exemption for referring to any foreign exchange. The original instruction-taking proposal cannot rely on that referral provision merely because a UK or EU provider executes the trade. (CNV Chapter III, art. 35.)
The recommended limited service should send employees to the provider's own order interface. The Argentine company can supply employer software and reconciliation, with separately agreed fees, while employees contract and instruct directly. It should have no authority to commit executable quotes, change orders, move principal or release tokens. The relevant provider and referral arrangement must satisfy Argentina's conditions and the separate UK territorial requirements. Read-only status integration still needs review of the actual data access and software permissions. (CNV Chapter III, arts. 2, 35 and 36.)
The strongest objection is that this separation may exist only in the documents. If the platform accepts the employee's order, promises settlement or controls the execution interface, the foreign provider may be performing the platform's own service. Where those facts establish that the Argentine company undertakes a listed PSAV service, it must register before operating or remove the regulated functions. Article 36 preserves responsibility for delegated performance; employee consent and prior wage payment cannot resolve the company's registration position.
The registered Argentine service and retained responsibility
Registration offers an alternative where the commercial proposition depends on controlling execution. The company must first satisfy corporate eligibility, categories and financial requirements. Article 7(b) specifies an Argentine sociedad anónima or sociedad de responsabilidad limitada with an express PSAV corporate object. The required minimum net assets are US$150,000 for Categories 1, 2 or 4 and US$75,000 for Category 3. Where several categories apply, the highest relevant requirement governs; the conditional 50% volume reduction must be established from the prescribed evidence. (CNV Chapter III, arts. 7(b), 9–11.)
A registered provider must implement the duties attached to its functions. These include reconstructable order records, IT controls, custody protections where relevant, segregated client fiat and prohibitions on using client assets for its own purposes. Price, spread and fee disclosures must match execution. Complaints, errors and failed transfers require defined handling. Article 19's permitted client-fund account arrangements do not supply an independent right to provide UK payment services. (CNV Chapter III, arts. 12–22, 25–32 and 39.)
A foreign execution partner requires an article 36 agreement, eligible regulatory and AML status, access to the required information and CNV notification. Delegation leaves the Argentine PSAV responsible for its service. The employer and employee contracts should identify which entity holds each asset, who owes delivery or refunds, and how the platform obtains records from the partner. A clause assigning all responsibility to the foreign provider would conflict with that retained obligation. (CNV Chapter III, art. 36.)
Argentine AML obligations also remain distinct from operational outsourcing. Argentina's financial intelligence unit requires a risk-based system, customer and beneficial-owner checks, monitoring and reporting under UIF Resolution 49/2024. Article 16 permits specified reliance on other obligated subjects listed in Law 25,246, article 20, subject to information, supervision and documentation conditions. A UK or EU provider's customer checks cannot automatically satisfy that rule. The Argentine PSAV must establish a lawful reliance basis or perform the required checks itself. (Law 25,246, art. 20(13); UIF Resolution 49/2024, arts. 3–6, 16, 21–37.)
Argentine fees, foreign exchange and asset reporting
The platform should receive only its own separately invoiced service revenue under the limited software design. Employer wage principal should remain in the UK payment chain, and purchase principal should pass from the employee to the permitted conversion provider. Collecting either amount in the Argentine company's operating account changes the client-fund and payment analysis. A software invoice cannot convert somebody else's principal into the company's service income. (CNV Chapter III, arts. 19–20; BCRA, Exterior y cambios, §§1.1–1.2 and 2.2.)
Argentina's central bank, the BCRA, generally requires covered service-export receipts to enter and be sold through the exchange market within 20 business days of the specified receipt or credit event. Offshore collection does not avoid that rule. The natural-person exception does not apply to this company, and the separate knowledge-economy corporate exception has conditions that the company must meet. The fee contract and accounting records should identify the service, payer, receipt date and applicable bank classification. (BCRA, Exterior y cambios, §§2.2.1–2.2.2, incorporating Communication A 8481.)
Adding an Argentine payment account would create another obstacle. BCRA's restriction for payment-service providers offering payment accounts covers carrying out or facilitating customer operations in digital assets lacking the specified national regulatory or BCRA authorisation. CNV registration of a provider does not itself approve its tokens. The company should therefore avoid introducing an Argentine payment-account product as a convenient place to collect GBP. (BCRA, Sistema nacional de pagos, Proveedores de servicios de pago, §4.6; CNV Chapter III, art. 37.)
Its own fees also require ordinary Argentine tax treatment. Foreign customers do not make a resident company's income exempt. Services-export VAT treatment depends on effective use abroad, and export invoicing must follow the applicable electronic-invoice requirements. The actual financial and software functions determine the classification; a UK billing address alone is insufficient. (Income Tax Law, text ordered by Decree 824/2019, arts. 1, 2 and 5; VAT Law, text ordered by Decree 280/1997, arts. 1(b) and 43; AFIP RG 4401/2019, arts. 1–2.)
Asset-platform reporting has an independent trigger. The current RG 4614 regime reaches relevant administration, management, control or processing of asset movements for domestic or foreign persons. It can include accounts hosted elsewhere but managed or controlled through the platform. An active integration cannot assign all reporting to its backend merely because that provider holds the account. A payroll service confined to data and reconciliation requires assessment against the actual trigger, rather than automatic treatment as an asset-account operator. (AFIP RG 4614/2019, arts. 3, 5 and 6, as amended by ARCA RG 5804/2025.)
Payroll data and evidence of performance
The employer should provide the Argentine service only with payroll data needed for its assigned functions. Its processor contract must specify documented instructions, confidentiality, security, subprocessors and assistance with compliance. A conversion provider deciding how to perform its own customer and AML obligations may have a separate controller role. Employee choice about purchasing tokens does not replace the need for a lawful basis for each use of personal information. (UK GDPR, arts. 5–6, 28 and 32.)
Argentina benefits from UK adequacy treatment for the relevant international transfer. That route can cover access by the separate Argentine support company without requiring a transfer agreement merely because the destination is Argentina. It does not dispense with the processor contract or security duties, and onward access from another country requires its own transfer analysis. The current statutory provisions are articles 44A and 45A, with Argentina's approval preserved by the Data Protection Act. (UK GDPR, arts. 44A–46; Data Protection Act 2018, Sch. 21, paras. 4–5(2)(c).)
The Argentine operation must also observe local security, confidentiality and processing limits. Support staff should receive role-based access, with access logs and a documented response to breaches. Payroll identifiers should remain off the public blockchain; the internal record can link the employee, instruction and transaction hash without publishing employment details. Retention should follow each applicable legal period and purpose, with deletion of unnecessary copies. (Argentine Law 25,326, arts. 9, 10, 16(5), 16(7) and 25; UK GDPR, arts. 5 and 32.)
The employer needs payslips, minimum-wage calculations, PAYE records and evidence of the agreed GBP credit. The provider needs the employee's order, quote, charges, ownership allocation, wallet checks and execution or refund record. Required NMW records must be kept for six years from the end of the following pay-reference period. PAYE records covered by regulation 97 must be preserved for at least three years after the relevant tax year ends. Argentine PSAV and UIF records can require at least ten years, with different starting events for transactions and customer files. A single deletion date measured from payroll processing would miss those distinctions. (ERA, s. 8; NMW Regulations, reg. 59; PAYE Regulations 2003, reg. 97; CNV Chapter III, art. 39; UIF Resolution 49/2024, art. 17.)
Contracts and launch conditions
The employer-platform agreement should preserve ordinary GBP payroll when the token service is unavailable. It should define the software functions, payment evidence, reconciliation, correction responsibilities and data access. Any direct token remuneration or additional award needs separate employment terms specifying the obligation, valuation, tax funding and performance event. A foreign governing-law clause cannot remove mandatory protection attached to the employee's habitual work in Great Britain. (ERA, ss. 1, 4, 8 and 13; assimilated Regulation (EC) 593/2008, art. 8.)
The employee-provider contract should state the maximum GBP spend, selected token and chain, quote validity, spread, fees and slippage limit. It should identify when the order becomes binding, when cancellation ends, when ownership passes and when delivery is due. Failed execution, a wrong address, a network outage, depeg and insolvency need separate treatment because they involve different promises and causes. Exclusions must preserve mandatory consumer rights and the provider's responsibility for its own performance. (Consumer Rights Act 2015, ss. 49, 57 and 62; CNV Chapter III, arts. 25–28, 32 and 37–38, where the provider is subject to those rules.)
Before onboarding, the company should approve a diagram of every monetary and token movement against the contracts and software permissions. It must match the legal entity on each official register to the required service, territory and role. The checks should distinguish a payment provider, crypto exchange, custodian and any registered agent. Where the Argentine company delegates its own PSAV service, the partner agreement must satisfy article 36 and preserve information access. (PSRs, regs. 25 and 34; MLRs, regs. 14A and 56; CNV Chapter III, arts. 9 and 36.)
Launch should follow completion of the employee communication route, tax treatment, data arrangements and failure procedures. Operational trials should demonstrate that rejected onboarding, an expired quote, missing transfer information or a provider outage leaves GBP payroll running. They should also demonstrate that the conversion process waits for actual salary receipt and refunds failed orders under the promised terms. (FSMA, s. 21; ITEPA, ss. 62 and 696; UK GDPR, art. 28; MLRs, regs. 64A–64G.)
The preferred launch preserves an employer subscription for payroll software and reconciliation while placing employee orders directly with the permitted provider. If the commercial service must accept orders or promise conversion, the Argentine company should pursue the registered alternative before retaining those functions. Redesign is also required if wages move to a platform-controlled balance before employee receipt, the platform collects principal or acquires withdrawal powers, or the selected token changes the applicable permission. Those facts alter the wage-discharge condition or the regulated service itself. (ERA, ss. 13 and 27; PSRs, Sch. 1; CNV Chapter III, arts. 1, 9, 35 and 36.)