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On Receipt of Capital Reward

Tax position for lender/staker where CAPITAL REWARDS received and there is a transfer of beneficial ownership
This is the tax position upon receipt of the capital reward, where it is not received at the time of exiting the yield generating activity or upon liquidation.

CGT disposal – ‘Marren v Ingles right' to receive capital reward tokens

When the capital reward tokens are received (usually this will be upon exit from the yield generating activity), a capital gains tax calculation is required to adjust for the difference between the estimated and actual market value of the capital reward tokens received.
At the time of entering the yield generating activity, the estimated future capital reward tokens were subjected to CGT. Upon entry, there was also an acquisition of ‘Marren v Ingles right' to receive an unascertainable future quantity of tokens. The acquisition cost of his ‘Marren v Ingles right' is the estimated value of the future reward which has been used in the capital gains tax calculation upon entry.
On receipt of the capital reward tokens, a further capital gains tax calculation is required. The disposal proceeds used in the calculation is the sterling market value of the capital reward tokens at the date of receipt. The acquisition cost is the estimate of the future capital reward, which was made upon entry. Where the estimate upon entry was too low, there will be a further capital gain upon receipt of the capital reward tokens. Where the estimate upon entry was too high, there will be a capital loss upon receipt of the capital reward.
Where the disposal of the ‘Marren v Ingles right’ gives rise to a capital loss, it may be possible to elect to set that loss against any capital gain that arose upon entry. For more information about this election HMRC point you to CG15080 onwards
HMRC Example 9 at CRYPTO61679 shows the capital gains computation where a loss is realised upon disposal of the 'Marren v Ingles right', at the time of receiving the reward tokens.

CGT acquisition – capital reward tokens

The acquisition cost of the capital reward tokens received is the sterling market value of the tokens at the date of receipt.
When the tokens are subsequently disposed of (let’s say sold for fiat for example), you will only pay further capital gains tax to the extent they appreciate in value between receiving the reward tokens and eventual disposal.
Equally, if they fall in value by the time they are disposed of, a capital loss will be realised. Unless in the same tax year, a capital loss cannot be carried back to reduce any earlier capital gain realised upon entry or exit from the yield generating activity.

Example

See our Example 1C illustrating the tax position at each point in the lifecycle of staking tokens where there is a transfer of beneficial ownership and capital rewards are received.