The UK tax authority, HM Revenue and Customs (HMRC), will introduce a “no gain, no loss” Capital Gains Tax (CGT) treatment for specified crypto transactions involving cryptoasset lending and liquidity pools. Under the policy, which is set to take effect on 6 April 2027, CGT is generally deferred until a participant makes an “economic disposal” of the underlying cryptocurrency.

HMRC says the change applies to individuals and trustees that enter relevant cryptoasset loan and liquidity pool arrangements. The rules amend the Taxation of Chargeable Gains Act 1992 and cover three main scenarios: (1) certain single cryptoasset lending arrangements where the interest is acquired or disposed of in exchange for cryptoassets of the same type; (2) borrowing arrangements in which borrowed cryptoassets are treated as acquired at market value at the time of borrowing, with collateral disregarded for CGT purposes; and (3) automated market-making via smart-contract liquidity pools, where “no gain, no loss” applies on exit to the extent participants receive the same quantity of the cryptoasset they initially invested, with differences triggering gains or losses.

HMRC states the approach aims to better align taxation with the economics of these DeFi structures and is expected to affect about 700,000 taxpayers.