> For the complete documentation index, see [llms.txt](https://docs.recap.io/uk-tax-guide-for-individuals/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.recap.io/uk-tax-guide-for-individuals/transaction-types/token-upgrades-swaps.md).

# Token Upgrades/Swaps

![](/files/qiHRKTc5LXTXNh7qTspm)

Here are three common scenarios arising for token upgrades/swaps. Let's use an example to consider the scenarios and their possible tax effect.

{% hint style="info" %}
Token A is upgraded to a newer version of that Token (let's say Token A v2).&#x20;
{% endhint %}

## **Airdropped upgrade**

The new Token A v2 will often be airdropped via a second smart contract.\
\
The original Token A may or may not continue to exist alongside the new Token A v2.

### Possible tax treatment

{% hint style="warning" %}
There is no specific HMRC guidance on the consequences of a token upgrade, but there is some guidance on transferring tokens between distributed ledgers at [CRYPTO22110](https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto22110).&#x20;

The specific circumstances of each occurrence need to be examined and it is recommended you seek [professional tax advice](https://www.wrightvigar.co.uk/services/crypto/) on the tax treatment.
{% endhint %}

It is possible the acquisition cost of the original Token A should apportioned between the original Token A and the new Token A v2, pro-rata, in accordance with the market value of each token at the date of the upgrade.&#x20;

If the original token becomes worthless at the date of the upgrade, then all of the acquisition cost will be moved over to the new token.

## Upgrade mechanism

You are required to send the original Token A to a certain address via a second smart contract. More often than not, the original Token A will get burned (destroyed). \
\
Under the second smart contract you receive the new Token A v2.&#x20;

### Possible tax treatment

{% hint style="warning" %}
There is no specific HMRC guidance on the consequences of a token upgrade, but there is some guidance on transferring tokens between distributed ledgers at [CRYPTO22110](https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto22110).&#x20;

The specific circumstances of each occurrence need to be examined and it is recommended you seek [professional tax advice](https://www.wrightvigar.co.uk/services/crypto/) on the tax treatment.
{% endhint %}

It is possible the acquisition cost of the original Token A will be moved over to the new token, since the original token no longer exists.

{% hint style="danger" %}
However it is possible HMRC may treat this as a disposal of the original token A for capital gains tax purposes.
{% endhint %}

## Redenomination upgrade

An alteration is made to the smart contract underlying the original Token A and it is also renamed Token A v2.

### Possible tax treatment

{% hint style="warning" %}
There is no specific HMRC guidance on the consequences of a token upgrade, but there is some guidance on transferring tokens between distributed ledgers at [CRYPTO22110](https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto22110).&#x20;

The specific circumstances of each occurrence need to be examined and it is recommended you seek [professional tax advice](https://www.wrightvigar.co.uk/services/crypto/) on the tax treatment.
{% endhint %}

It is possible the acquisition cost of the original Token A will be moved over to the new token, since the new Token A v2 has replaced the original Token A.&#x20;
