What happened?
HMRC published GfC21 on 15 October 2026 and clarified its business-customer and digital-service sections on 21 October. This is guidance on existing rules, not a new cryptoasset VAT regime.
Key details
Treatment depends on the underlying supply, customer status and location. The guidance addresses registration, reverse charge, evidence and platform responsibilities. Business-to-business place-of-supply analysis remains subject to applicable use-and-enjoyment rules.
Business impact
T&M analysis: a GCC seller should map the actual goods, rights or services supplied before assessing UK VAT exposure. Wallet records alone may leave the customer-location and business-status questions unanswered. Collect appropriate evidence at checkout and keep it with the transaction record.
Platforms should compare their contracts with what they actually control, including charging, delivery and sale terms. Do not assume direct payment to a creator settles who must account for VAT. Distinguish VAT compliance from separate cryptoasset information-reporting obligations.
What happens next?
Review the detailed HMRC guidance and linked VAT notices for the specific transaction. Document the decision on registration, reverse charge and platform liability; avoid applying one answer to every token type. News and analysis only; not tax, legal or investment advice.
Sources
Primary and secondary sources are distinguished below. See our methodology for verification and correction standards.