Earnings from staking, mining and airdrops sit in a different category from simple buy-and-hold investing, and the rules differ from those for disposals. HMRC's Cryptoassets Manual sets out the general framework, although in practice the analysis depends on the specifics of each protocol and how the activity is conducted.
Mining
Mining rewards are taxable when the tokens are received, with the sterling value at the date of receipt forming the taxable amount. The question is whether the activity amounts to a trade or is miscellaneous (other taxable) income.
- Hobby or miscellaneous income: An individual mining occasionally with consumer hardware will typically have miscellaneous income, taxable under the "other income" rules. Limited deductions are available, primarily for direct costs such as electricity attributable to the activity.
- Trade: Where mining is conducted on a commercial scale, with significant capital investment, organisation and the intention to make profit, it can amount to a trade. Trading profits are subject to income tax and Class 4 NICs for individuals, or corporation tax for companies, and a wider set of deductions becomes available, including capital allowances on mining hardware.
On a later disposal of the mined tokens, the cost basis for CGT is the sterling value at the date the tokens were received (already taxed as income). This avoids double taxation on the same value.
Staking
Staking rewards are also generally taxable as income on receipt at sterling value. The exact analysis varies with the staking model. Pure delegated staking on a major proof-of-stake chain is typically miscellaneous income. Running a validator node at scale, with technical infrastructure and a commercial operation, can amount to a trade.
HMRC's published guidance recognises a distinction between staking rewards that are predictable and contractual on the one hand, and rewards that are more speculative and discretionary on the other. The former may look more like financial income, the latter more like miscellaneous income. The tax effect is similar in most cases for individuals: the receipt is taxable as income on receipt, and the sterling value sets the cost basis for the eventual disposal.
Liquidity provision and DeFi
Decentralised finance complicates the picture. Where a user deposits tokens into a liquidity pool and receives LP tokens in return, the deposit may itself be a disposal under HMRC's "beneficial ownership" approach if the LP token represents different rights from the underlying. Yield earned in the pool is then taxable as income on receipt, with a further CGT event when the LP token is redeemed. Our detailed DeFi piece covers this in more depth.
Airdrops
Airdrops are tokens distributed, often for free, by a protocol to existing or potential users. The HMRC treatment depends on whether anything was required in return.
- Pure gift airdrops: Tokens received without doing anything in return, and not in the course of a trade, are not generally taxable as income on receipt. There is no immediate income tax charge. CGT applies on disposal, with a cost basis of nil unless a market value at receipt can be established.
- Airdrops in return for a service: Tokens received because the recipient performed an action (testing a protocol, providing referrals, completing a quest) are taxable as miscellaneous income at sterling value on receipt. Some airdrops fall here even though the recipient did not see themselves as performing a service.
- Trade-related airdrops: Tokens received in the course of a trade are trading receipts and taxed accordingly.
Hard forks
When a blockchain forks and the holder receives tokens on the new chain, HMRC does not treat the receipt as immediately taxable income. The original cost basis is split between the old and new asset on a just-and-reasonable basis, and CGT is computed in the usual way on later disposals.
Reporting
Income from staking, mining and taxable airdrops is reported through Self Assessment. Where the amounts are modest and miscellaneous, the trading allowance of £1,000 may shelter small receipts. Where the activity amounts to a trade, full trading accounts and computations are required. CGT on later disposals is reported through the capital gains pages.
How we help
PushDigits works with UK-resident crypto holders to characterise staking and mining income correctly, run the dual income-tax and CGT analyses required, and prepare the resulting Self Assessment or company tax returns. Visit our Self Assessment and tax planning pages, or contact us to talk through your activity.
