UK Crypto Loans and Liquidity Pools: No Gain, No Loss CGT Rules from 6 April 2027

On 13 July 2026 HMRC published draft Finance Bill 2026-27 legislation on the tax treatment of cryptoasset loans and liquidity pools. From 6 April 2027, certain disposals by individuals and trustees into and out of qualifying arrangements will be treated as no gain, no loss (NGNL) for Capital Gains Tax — aligning the tax point more closely with an economic disposal of the underlying cryptoasset.

The measure follows HMRC’s 2022 guidance, a 2022 call for evidence, a 2023 consultation, and a Budget 2025 summary of responses. Technical consultation on draft clauses sits in the same Finance Bill window closing 7 September 2026. HMRC estimates around 700,000 individuals engage in cryptoasset loan and liquidity pool transactions.

Single cryptoasset lending arrangements: where you have a right to receive a number of qualifying cryptoassets plus a return economically equivalent to lending, acquiring or disposing of an interest for cryptoassets of the same type as the invested assets is treated on an NGNL basis.

Single cryptoasset borrowing arrangements: borrowed qualifying cryptoassets are treated as acquired at market value; returning the same type is treated as a disposal at that same value. Collateral provided under the borrowing is disregarded for CGT.

Automated market making (liquidity pool) arrangements: depositing qualifying cryptoassets into a smart-contract pool for an interest is NGNL where the assets match the invested types. Withdrawing is NGNL to the extent you receive the same quantity originally invested; any excess or shortfall crystallises a gain or loss by reference to that difference.

Map wallets and DeFi positions now: which balances sit in lending protocols, which in AMM pools, and which are simply held. Segregate eligible stablecoin balances — the parallel stablecoin draft treats qualifying tokens more like money from April 2027, and NGNL rules are modified so gains on exempt assets cannot be rolled into non-exempt assets and vice versa.

If you advise clients or hold material DeFi positions, review the draft legislation and explanatory note before the 7 September 2026 consultation close. Questions for HMRC often focus on quantity mismatches on withdrawal, multi-token pool economics, and record-keeping evidence for NGNL claims.

Keep transaction histories exportable. Soft-landing or deferred recognition only helps if you can prove what entered and left each arrangement.

Organised transaction packs make Self Assessment review faster when DeFi activity grows. FinnAccountings helps UK and Irish businesses and sole traders prepare bookkeeping and tax packs with Chartered Accountant insight before you or your ICAEW/ACCA or Chartered Accountant (Ireland) adviser files. Start a free trial for review-ready drafts — we prepare records; we do not file Self Assessment or compute CGT disposals on your behalf.

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Pair this measure with the stablecoin reform published on the same Legislation Day — eligible tokens move toward money-like treatment from April 2027.

UK stablecoin tax reform from April 2027 →

For the wider Finance Bill 2026-27 draft package and 7 September consultation close, read the Legislation Day overview.

UK Finance Bill 2026-27 Legislation Day overview →

Use the dual-market tax calculator for high-level Income Tax planning only — not crypto CGT computations.

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