HMRC has recently revised its published guidance in relation to cryptoassets. The revised guidance includes interesting commentary on the situs of "exchange tokens", more commonly known as cryptocurrency - i.e. where such assets are situated as a matter of law.

Why does it matter?

In a UK tax context, the question of whether an asset is situated within or outside the UK has a number of ramifications. Inter alia:

(1) For an individual who is domiciled outside the UK and is using the remittance basis, a gain realised on the disposal of a UK situs asset is immediately chargeable to capital gains ...