Source of cryptoasset income: part two

In my article ‘Where’s Wallet?’ (Taxation 3 November 2022) I discussed the topic of situs for CGT and IHT in the context of cryptoassets. Since then case law has moved on and perhaps my own thinking has been refined.

However I don’t want to spend too much time covering that same ground again. This is a discussion of how to determine the source of crypto income and not the situs of assets for either CGT or IHT purposes. I have set out my view on situs in summary at Figure 1. This will be relevant when determining the source of income in some scenarios.

It should be noted that there is still scope for debate on situs in particular around the situs of permissionless tokens that are not held through a centralised exchange. In this regard I have set out a table (see Table 1)...