Situs of cryptoassets

This article has shamelessly stolen its title from the Where’s Wally? (Where’s Waldo? if you’re from across the pond) books by English illustrator Martin Handford. As you may know the reader simply had to find the eponymous miniature character amongst a sea of similarly minute characters in various scenes. Spotting Wally in his red and white striped jumper was not as easy as you might think – with plenty of fiendish decoys thrown in for good measure.

Arguably determining the situs of cryptoassets and the source of any income they produce can be even more difficult. There are no tell-tale stripey jumpers but there are certainly a few decoy views added to the mix!

This article will consider the situs of assets for CGT and IHT purposes.

Overview

Situs is a concept of general international law and is used to determine the location...