HM Revenue and Customs published the outcome of its call for evidence on the taxation of stablecoins on 13 July 2026, confirming that the government will legislate to treat eligible stablecoins more like money for Capital Gains Tax, Income Tax and Corporation Tax purposes. Draft legislation was released alongside the response for an eight-week technical consultation. The measures are to be carried in Finance Bill 2026-27 and are intended to take effect from April 2027. A separate HMRC policy paper published the same day, Cryptoasset loans and liquidity pools, sets out draft legislation deferring Capital Gains Tax until an economic disposal of the cryptoasset occurs.
For individuals, HMRC states that a full Capital Gains Tax exemption is the preferred approach for the taxation of eligible stablecoins, removing disposals of those tokens from the charge under the Taxation of Chargeable Gains Act 1992. Interest-like returns from the lending of eligible stablecoins are to be taxed on individuals in the same way as interest on fiat currency savings. For companies, eligible stablecoins will be treated as giving rise to a money debt, and the lending of eligible stablecoins will constitute a transaction for the lending of money for the purposes of the loan relationship rules in Part 5 of the Corporation Tax Act 2009. The cryptoasset loans and liquidity pools legislation applies to single cryptoasset lending arrangements, single cryptoasset borrowing arrangements, and automated market making arrangements.
UK-resident individual holders of backed stablecoins move from a chargeable gains computation on every disposal to an exemption, ending pooling and share matching calculations for those tokens from April 2027. Centralised exchanges and lending platforms serving UK customers must separate eligible stablecoins from other cryptoassets in transaction reporting, because the two categories attract different charges. Corporate treasury functions holding stablecoins will bring those balances within loan relationship accounting rather than the chargeable gains rules, changing the timing and character of taxable amounts. Decentralised finance users depositing tokens into liquidity pools obtain deferral of Capital Gains Tax until an economic disposal rather than a charge on each pool entry and exit.
Unbacked algorithmic stablecoins are outside the intended scope. HMRC states that there should be substantial assets held backing the stablecoin to support its value, and the eligibility test draws on the regulatory definition. Two questions were left open at the point of publication: the application of withholding tax, and whether the cryptoasset loan rules will have retrospective effect. The technical consultation on the draft legislation ran for eight weeks from 13 July 2026, and the measures depend on the passage of Finance Bill 2026-27 before the April 2027 commencement date.
Licentium advises token issuers, exchanges, lending platforms and corporate treasury functions on the tax and regulatory treatment of digital assets in the United Kingdom and the European Union. We can review how the proposed stablecoin and cryptoasset lending rules affect your product terms, customer reporting and accounting positions ahead of April 2027. Work we undertake includes stablecoin eligibility analysis, Capital Gains Tax and loan relationship treatment reviews, technical consultation responses to HMRC, customer tax reporting design for exchanges and custodians, and structuring advice for lending and liquidity provision arrangements.