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Taxing token generation events

Taxing token generation events (ICOs) is notoriously uncertain. Ben Jones, Kunal Nathwani, Andrew Henderson and James Burnie (Eversheds Sutherland) review some of the key issues.
 

The concept of attributing monetary value to data held on code i.e. ‘cryptocurrency’ has existed since the 1980s arguably originating with DigiCash. Recently blockchain technology has changed the way data may be held using a distributed ledger. This safer more secure way of holding a piece of data referred to in this article as a ‘token’ has led to increasing popularity and global acceptance of the concept of using cryptocurrencies.

The increased acceptance of cryptocurrencies as a new asset class has led regulators and tax authorities to consider how such cryptocurrencies should be treated. HMRC accepts that cryptocurrencies as an asset class have ‘unique characteristics’ which are not entirely comparable with other existing asset classes or payment methods...

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