HMRC does not consider the return (see CRYPTO61130) earned by the lender/liquidity provider to be ‘interest’ for tax purposes (see CRYPTO61110). Consequently, any provisions in the Taxes Acts which apply to interest will not apply to the return. In addition, HMRC does not expect that the lending/staking of tokens by a customer subject to Corporation Tax will be a loan relationship (see CRYPTO41100). How the return is taxed will depend on whether the receipt has the nature of capital or revenue. For guidance on determining the nature of the return, see CRYPTO61414 and CRYPTO61214.