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Situs of cryptocurrency utility tokens

Where are utility tokens emitted by a foreign entity and owned by a UK resident located?

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Hello,

In this latest guidance, HMRC announced that they consider the situs of exchange tokens such as bitcoin to be that of their owner. https://www.gov.uk/government/publications/tax-on-cryptoassets/cryptoass...

However, HMRC distinguishes between exchange tokens, utility tokens and security tokens. They only provided guidance for the first but not the two lasts.

What would be the situs token for utility tokens? Is it possible for an individual to ask for HMRC's take on the subject despite the lack of public guidance? That would affect taxation of non-dom residents for example as well as bankrupcy proceedings of companies.

This paper seems to suggest that the location of a utility token would be that of the entity that emits it (pages 11 to 16): https://www.citysolicitors.org.uk/storage/2019/06/Financial-Law-Committe...

Thank you for reading.

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