HMRC has updated its guidance on crypto assets which expands its thinking in various areas.
My view is this is work in progress, as I think there will be many and significant changes in the months and years ahead, which reflects the fast moving nature of crypto.
In particular, I think further work will be required in the area of situs for non domiciles - many non doms are currently investing in crypto unaware that HMRC regard them as UK situs, when the beneficial owner is UK resident.
The aim of this manual is to help people understand the tax implications that can arise from transactions involving cryptoassets. It is written for HMRC staff but may also assist customers and their professional advisers in understanding HMRC’s interpretation of the law as it relates to cryptoassets as at the date of publication.
https://www.gov.uk/hmrc-internal-manuals/cryptoassets-manual