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Posted Mon, 21 Aug 2023 18:30:58 GMT by
Hi, I have read the personal tax guidance on token airdrops as outlined here https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual/crypto21250 but I'm hoping to gain further clarity on a specific scenario that pertains to me as i'm a little lost. I became eligible for an airdrop from Arbitrum, which was a complete surprise to me as I had no prior knowledge of its occurrence. My engagement with the Arbitrum network was purely routine, including activities like trading coins and purchasing NFTs. It was only after the fact that I discovered I was eligible for this airdrop, as there had been no publicly disclosed information about it before the snapshot was taken. Given these circumstances, I'm uncertain whether this would fall under Income Tax? My actions on the network weren't driven by the anticipation of financial gain from such an airdrop, which makes me question its classification. Additionally, I did claim the airdrop once I became aware of it. If that has any bearing on the tax implications, I'd appreciate insights on that as well. Switching gears to capital gains tax, I'm curious about its application in this context. Is the taxable event determined by the difference between the time I claimed the airdrop and when I converted it to another token (e.g., USDC)? Alternatively, is the airdropped token considered to have an initial value of 0, making any subsequent gain from its sale subject to CGT? Any guidance on this would be much appreciated as I'm struggling to find any further clarification when searching.
Posted Thu, 24 Aug 2023 15:34:08 GMT by HMRC Admin 25 Response
Hi JerremyJ,
Based on what you have stated, you are not 'trading' as such so would potentially be chargeable under miscellaneous income.
The acquisition date would be the date he became eligible to receive the 'Air drop' & the value taxable as miscellaneous income  would be what the drop was worth at the same date.
This would also be his acquisition cost if/when he disposes of the coins & will be chargeable to CG on the difference between this & the disposal amount.
BIM100150 - Miscellaneous income: calculating the profits
Thank you. 
Posted Thu, 24 Aug 2023 16:33:04 GMT by
Thank you for your insight in to this. I'm clear on how the airdrops value is correlated now but am still a little unclear on the income tax for said airdrop as you stated that it would 'potentially be charageable', is there any way to get clarity on what would make it chargeable as income tax and what would not? In the official guidance it says: "Income Tax may not apply if they’re received: - without doing anything in return (for example, not related to any service or other conditions) - not as part of a trade or business involving cryptoasset exchange tokens or mining" Does that mean that any airdrop in regards to using blockchain layers that gets rewarded for use of the product is considered income tax, e.g. the Arbitrum airdrop, the uniswap airdrop etc. But that airdrops related to holding an asset like an NFT e.g. the ENS domains airdrop are not charageable as income tax? I understand that this is an ever evolving field and there are many different types but based upon these 2 different types; rewards for using a service - uniswap and arbitrum (often consider retroactive airdrops); and being rewarded for holding an asset. How would they be seen? (As these to my knowledge are the most common cases for airdrops). Another post in your forum asks about retroactive airdrops as the example above and was told that no income tax applies, thus my confusion: https://community.hmrc.gov.uk/customerforums/pt/810ef25d-802c-ee11-a81c-000d3a0d1621#27d4f85d-802c-ee11-bdf4-00224840d928 Thanks again, I really appreciate your insight on this.

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