Is moving Bitcoin between my own wallets a UK disposal?

No. HMRC's disposals are selling tokens for money, exchanging them for another type of token, using them to pay for goods or services, and giving them away, the last subject to spouse, civil-partner and charity exceptions. There is no disposal where the individual retains beneficial ownership throughout, for example moving tokens between public addresses that the individual beneficially controls.

How does the Section 104 pool actually work?

Each token type needs its own pool holding a quantity and a pooled allowable cost. The pool rises with acquisitions the same-day and 30-day rules do not take, and falls proportionately on disposal. Sell 0.25 BTC from a 1.00 BTC pool costing £40,000 and £10,000 of allowable cost is relieved, leaving 0.75 BTC and £30,000.

Is a Bitcoin network fee deductible in the UK?

HMRC accepts transaction fees paid for inclusion on the distributed ledger as an allowable cost. A fee satisfied in tokens is also a disposal in its own right, so the tokens handed over are disposed of at market value and their own allowable cost comes from the same identification sequence.

Is mined Bitcoin taxed twice in the UK?

It should not be. Outside a trade, the sterling value at the time of receipt is miscellaneous income, and that same value is what enters the pool as allowable cost. Where Income Tax has been paid on part of the token value, Capital Gains Tax is charged only on the increase since receipt.

Bitcoin Tax in the UK: Section 104 Pooling, Mining and CARF

Q: Do the same matching rules apply to a company?

No. The 30-day rule is enacted for the purposes of capital gains tax but not corporation tax. A company gets a same-day rule, then matches a disposal against acquisitions in the previous nine days, first in, first out, so backwards over ten days rather than forwards over thirty.

Ask a Bitcoin wallet which coins it just spent and it names specific transaction outputs. Ask HMRC and the question is beside the point: Bitcoin tax in the UK does not work by tracing the coins that left the wallet. A disposal runs through a statutory identification sequence instead.

That sequence matches the disposal against acquisitions of the same token type on the same day, then in the following 30 days, and only then against the Section 104 pool. HMRC CRYPTO22200

The blockchain and the tax computation tell two different stories about one transaction, and both are correct.

UK disposals are matched in a fixed order

For individuals, acquisitions are matched against a disposal in this sequence, never by picking coins.

Same-day ruleAcquisitions on the same day as the disposal are matched first.
The following 30 daysThen acquisitions in the 30 days after the disposal, earliest first.
Section 104 poolEverything else sits in a pooled average-cost holding.

Who and what the rules reach

IndividualsCapital gains tax, using this matching order
CompaniesCorporation tax, a different regime; do not assume this order
MiningTrading or miscellaneous income, depending on the facts
CARFUK obligations commenced 1 January 2026

Theft is not a disposal. The victim may retain legal title and recovery rights, so the analysis is not simply a loss claim.

Scope and date. What a UK-resident individual pays on personally held BTC, plus the mining, employment, Value Added Tax (VAT), filing and reporting rules around it, against HMRC guidance and UK legislation reviewed to August 30, 2026. Capital Gains Tax (CGT) is charged on the gain when a chargeable asset is disposed of, and the tax year runs 6 April to 5 April. HMRC, selling cryptoassets Educational research, not personal tax advice.

A company does not use the rules on this page. The 30-day rule in the Taxation of Chargeable Gains Act 1992 (TCGA 1992) is enacted "for the purposes of capital gains tax (but not corporation tax)". TCGA 1992 s. 106A(1) HMRC confirms "slight differences between the pooling rules as they apply for Capital Gains Tax and Corporation Tax purposes": a company gets a same-day rule, then matches a disposal against acquisitions in the previous nine days, first in, first out: backwards over ten days, not forwards over thirty. HMRC CRYPTO41350 Tokens a trading company takes from customers or pays to suppliers run through taxable trading profits instead, charged to Income Tax or Corporation Tax. HMRC CRYPTO40350 Compute a company from HMRC's corporation tax pages. HMRC CRYPTO41000

1. Bitcoin tax in the UK: investment or trade?

For individuals, HMRC's position is that in the vast majority of cases cryptoassets such as Bitcoin are a personal investment, so disposals fall within Capital Gains Tax; a financial trade is possible but "likely to be unusual", and where one exists Income Tax rules take priority. HMRC CRYPTO20050

Mining, employment and lending receipts produce income independently of any later capital gain, so one person can have both: income on receipt, then a gain or loss on disposal. HMRC, receiving cryptoassets

2. What is a disposal, and what is not

HMRC's disposals are selling tokens for money, exchanging them for another type of token, using them to pay for goods or services, and giving them away, the last subject to spouse, civil-partner and charity exceptions. Moving BTC between addresses the same person beneficially owns is not one: "There is no disposal if the individual retains beneficial ownership of the tokens throughout the transaction, for example moving tokens between public addresses that the individual beneficially controls." HMRC CRYPTO22100

That matters more in Bitcoin than in most assets: a wallet spends unspent transaction outputs (UTXOs), discrete chunks of BTC created by earlier transactions, and ordinary use consumes them, creates change and consolidates balances constantly, none of it taxable. A UTXO is a protocol object; a Section 104 pool is a tax construct aggregating allowable cost after the identification rules have run. Treat a change output as a fresh acquisition and you manufacture one that never happened, so preserve the pool through wallet restructurings.

3. The identification order

Buying BTC with pounds is an acquisition, not a chargeable event: the cost is recorded and the tokens enter their Section 104 pool unless a matching rule pulls them back out. HMRC CRYPTO22200 Identification then runs in a mandatory order.

Same day (TCGA 1992 s. 105). All tokens of that type acquired on the day in the same capacity count as one acquisition and all disposed of as one disposal, matched as far as possible before the pool is touched; any excess drops to step 2, then 3.
The following 30 days (TCGA 1992 s. 106A). BTC of the same type acquired in the same capacity within 30 days after a disposal is matched to that disposal, earliest first, instead of entering the pool. Without this "bed and breakfast" rule a taxpayer could sell and rebuy to crystallise a result while keeping the position.
The Section 104 pool (TCGA 1992 s. 104). Everything the first two steps leave. Each token type needs its own pool of a quantity and a pooled allowable cost, rising with unmatched acquisitions and falling proportionately on disposal. Non-fungible tokens are separately identifiable, so they are neither pooled nor matched. HMRC CRYPTO22200

4. A worked Section 104 disposal

An individual holds 1.00 BTC in the pool at a pooled allowable cost of £40,000, and sells 0.25 BTC for £20,000 with no same-day or 30-day acquisitions, so the whole disposal matches to the pool:

£40,000 x 0.25 / 1.00 = £10,000 allowable cost

£20,000 - £10,000 = £10,000 illustrative gain, before other allowable amounts

The pool becomes 0.75 BTC and £30,000.

5. Selling, swapping, spending, giving

Bitcoin tax in the UK measures every disposal in pound sterling: the gain is proceeds, or sterling market value where no money changes hands, less the allowable cost the identification rules produce plus other allowable costs. A swap of BTC for ether (ETH) is therefore a disposal of the Bitcoin, with the ETH a separate asset carrying its own pool: "the crypto stayed inside the portfolio" is not an exemption, and this is how taxpayers end up with a tax bill and no pounds to pay it. Spending works the same way: a phone bought with BTC worth £1,200 against £800 of allocated allowable cost leaves an illustrative £400 gain. A gift is generally a market-value disposal, while tokens donated to a charity carry no Capital Gains Tax unless the donation is tainted or consideration above acquisition cost realises a gain. HMRC CRYPTO22100

An exchange's own report is not a computation: HMRC says such reports "are not tax calculations" and "will not keep track of your pooled costs". HMRC, selling cryptoassets No single venue can maintain a pool spanning the taxpayer's other exchanges and wallets, so matching runs across all platforms. An exchange-by-exchange calculation is wrong.

6. Fees, including the fee that is itself a disposal

Section 38 TCGA 1992 sets what is deductible, and HMRC's view is that it covers the sterling consideration originally paid, transaction fees paid for inclusion on the distributed ledger, advertising, professional costs of the contract, and valuation or apportionment costs. Some exchange fees qualify and some do not, and anything already deducted against Income Tax profits cannot be deducted again. HMRC CRYPTO22150

A fee satisfied in tokens is a cost and a disposal. HMRC requires you to "consider that fee as one of the costs for the disposal of the tokens, but you also need to consider the fee as a disposal in its own right": the tokens handed over are disposed of at market value under TCGA 1992 s. 17(1)(b), being given in consideration for a service, and their own allowable cost comes from the same identification sequence. Same token type on the same day, and the same-day rule collapses both legs into one computation; different token types (an exchange's own fee token) and two computations are required. HMRC CRYPTO22280 So BTC spent as a fee is tracked as its own disposal in the records, with its own quantity and cost relieved from the pool, even where the same-day rule presents both legs in one computation.

7. Mining Bitcoin in the UK

Whether mining is a trade turns on degree of activity, organisation, risk and commerciality: a home computer's spare capacity would not normally be a trade, a bank of dedicated machines run for expected net profit probably would, and a trade's profits follow the normal tax rules. HMRC CRYPTO40200 Outside a trade the pound sterling value at the time of receipt of the tokens awarded is miscellaneous income, with appropriate expenses reducing the amount chargeable. HMRC CRYPTO21150

Equipment and electricity fail section 38(1)(a) and are not allowable against the tokens for Capital Gains Tax, not being incurred wholly and exclusively to acquire them; they may instead be deductible against Income Tax profits, and the equipment's own cost may be allowable when the equipment is later sold, subject to the chattels and wasting-assets exemptions. HMRC CRYPTO22150 Capital allowances are "a type of tax relief for businesses", claimed under the general business rules where the activity is a trade. GOV.UK, capital allowances

income at receipt -> later disposal calculation

The link between the stages is the value already taxed as income. HMRC puts it both ways: "If you've paid Income Tax on any part of your cryptoasset token value, then you will not pay Capital Gains Tax on that amount" HMRC, selling cryptoassets, and "calculate Capital Gains Tax as normal on any increase in the value of the tokens since you received them" HMRC, receiving cryptoassets. In a pooled computation that means entering mined BTC at the sterling value taken into income on receipt and measuring the disposal against that figure, not nil, and not a later price. Miss it and the same gain is taxed twice.

A mining trade arrives differently: the tokens form trading stock, and on transfer out the business is treated as having bought them at the value used in the trading accounts, which becomes the allowable cost. HMRC CRYPTO22150 No reviewed HMRC material models pooling for every pay-per-share (PPS), full-pay-per-share (FPPS), share-accrual or payout-threshold arrangement, so commercial pools need their own analysis.

8. Employment income paid in Bitcoin

Cryptoassets received from employment are "money's worth", and exchange tokens like bitcoin are readily convertible assets, so a UK employer operates Pay As You Earn (PAYE) and National Insurance contributions before the tokens reach the employee, estimating their value and deducting from other wages. Checking that the right tax reaches HMRC stays the employee's responsibility, and where the tokens are not readily convertible assets and the employer has not operated PAYE the employee pays the Income Tax through Self Assessment. A later disposal is analysed under the capital-gains rules on the increase in value since receipt. HMRC, receiving cryptoassets

9. Lost keys and theft

Losing a private key is not a disposal. "Misplacing the key does not count as a disposal for Capital Gains Tax purposes." Where there is shown to be no prospect of recovering the key or the tokens, a negligible value claim can be made, and if HMRC accepts it the individual is treated as having disposed of and reacquired them, crystallising a loss. HMRC CRYPTO22400

Theft is not a disposal. "HMRC does not consider theft to be a disposal, as the individual still owns the stolen asset and has a right to recover it." The consequence follows directly: victims of theft cannot claim a loss for Capital Gains Tax on the theft. Negligible value is a separate route: open where an individual contracted for tokens, received them and they later became worthless, but not where they were worthless when acquired. HMRC CRYPTO22450 Because tokens are pooled, such a claim covers the whole Section 104 pool rather than individual tokens. HMRC CRYPTO22500

10. Lending and DeFi (decentralised finance): current law, then the announced 2027 measure

Under current rules, if the contract transfers beneficial ownership the lender disposes of the tokens for a right to receive future tokens; on repayment those tokens are a capital sum derived from that right and a disposal of it, the computation depending on the original treatment. HMRC CRYPTO61620 HMRC CRYPTO61650 A borrower transferring BTC to satisfy principal or a return disposes of those tokens too. HMRC CRYPTO61650 Outside a trade, the lender's return (as distinct from repayment of principal) is miscellaneous income at the tokens' sterling value. HMRC CRYPTO61213

On July 13, 2026 HMRC published a policy paper and draft legislation for certain single-cryptoasset lending, borrowing and automated-market-making arrangements, intended to apply from April 6, 2027 and to give qualifying transfers no-gain/no-loss treatment, deferring Capital Gains Tax until an economic disposal. It reaches individuals and trustees only: the draft clause applies where "a person other than a company" disposes of or acquires qualifying cryptoassets. HMRC policy paper Draft legislation

Announced is not enacted. The 2027 measure is not the rule for transactions taking place now, and a 2026 disposal is computed under the current law above.

11. VAT and Bitcoin

VAT, the consumption tax on supplies of goods and services, is a separate system, so a Bitcoin transaction can sit inside it and outside the others. VAT is due in the normal way on taxable goods or services sold for exchange tokens, at the sterling value of the tokens when the transaction takes place, and none on the supply of the token itself in that exchange. Mining rewards are generally outside the scope, not being an economic activity for VAT: insufficient link between service and consideration, and no customer. Qualifying services exchanging bitcoin for legal tender and back are exempt financial services, following the Court of Justice of the European Union (CJEU) decision in Hedqvist (C-264/14), an exemption attaching to the exchange service, not to goods a customer pays for in BTC. HMRC calls these treatments "provisional pending further developments". HMRC CRYPTO45000

12. Records, and where the gain goes on the return

HMRC requires separate records per pool and per transaction: token type, disposal date, number disposed of, number left, sterling value, bank statements, and pooled costs before and after. The gain goes in one of two places: a Self Assessment tax return after the tax year ends (in pound sterling, in the cryptoasset section, "available on returns for the tax year 2024 to 2025 onwards") or the Capital Gains Tax real time service. Reporting and payment are required where total gains for the year exceed the Capital Gains Tax tax-free allowance; unpaid tax for earlier years goes through HMRC's Cryptoasset Disclosure Service. HMRC, selling cryptoassets

The bookkeeping that has to sit underneath those records is the subject of our Bitcoin accounting reconciliation guide.

13. CARF now reaches UK-resident users

The Cryptoasset Reporting Framework (CARF), derived from Organisation for Economic Co-operation and Development (OECD) model rules, makes cryptoasset service providers collect and report user and transaction data to tax authorities. Its UK rules took effect on January 1, 2026, the date fixed by the Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 (SI 2025/744), a statutory instrument, not by the HMRC guidance page, which states no such date. SI 2025/744

The scope was then widened. Finance Act 2026 (c. 11) section 275, in force March 18, 2026 and headed "Cryptoasset reporting: users and controlling persons resident in the UK", applies the regulation 6 reporting duty to "cryptoasset users resident in the United Kingdom, or who have controlling persons that are resident in the United Kingdom", as it applies to reportable (non-UK) users, and applies the regulation 8 notification duty to them; regulation 3(1)(b) is read as Section I(C) to (G) rather than (C) to (H), and "resident" means resident for income tax or corporation tax purposes. Calendar 2026, the first reportable period, sits entirely inside the widened duty, so UK CARF is not a cross-border-exchange regime only: a UK provider reports its UK-resident users to HMRC too.

UK-based providers register and notify users by January 31, 2027, then file that first report between January 1 and May 31, 2027, dates on a guidance page last updated January 1, 2026, which predates section 275 and does not reflect it. HMRC CARF guidance

CARF calculates nothing for the individual. Users must give every provider they use, UK-based or not, their name, date of birth, address, country of residence and a tax identification number such as a National Insurance number or Unique Taxpayer Reference; inaccurate or missing details to a UK provider carry a penalty of up to £300. Where a UK resident uses a UK provider, HMRC links the activity to the tax record; where either side is abroad, information moves between participating authorities. HMRC, information you'll need to give UK cryptoasset service providers

Practical takeaway

For a UK-resident individual holding Bitcoin as an investment:

same day -> following 30 days -> Section 104 pool.

For a company, stop: corporation tax pooling runs same-day and then nine days backwards. HMRC CRYPTO41350

Everything else starts with identifying the receipt or disposal, then carrying any sterling value already taxed as income into the pool so it is not taxed twice. The wallet selects UTXOs, HMRC's rules select allowable cost, and the two must be reconciled rather than merged.

Where the manual leaves gaps (Lightning mechanics, mining-pool accruals, collateral liquidation, sends to unspendable outputs, custodian failures, reorganisation timing), the answer comes from general tax law and the taxpayer's legal rights, not the blockchain.

Bitcoin tax in the UK is one of four country guides in this series; the three sister guides answer the same questions under different law: Bitcoin tax in Canada, Bitcoin tax in the United States and Bitcoin tax in the EU. Our crypto tax accounting guide covers the subledger work that every one of them depends on.

Sources and further reading

Every URL below is also attached inline to the sentence it supports.

Educational research only. UK tax treatment depends on the taxpayer's status, entity type, facts, current law and the specific transaction.