EigenLayer & Restaking Tax UK: How HMRC Treats LRTs, Points and AVS Rewards

Restaking is the fastest-moving corner of Ethereum DeFi and the most confusing for UK Self Assessment. The good news is that HMRC's existing framework actually maps onto restaking cleanly once you separate the three taxable layers: the wrap, the rewards, and the points.

Layer 1: wrapping ETH into a liquid restaking token

Depositing ETH (or stETH) into Ether.fi, Renzo, or KelpDAO to receive eETH, ezETH, or rsETH is a disposal of the underlying asset. The proceeds figure is the GBP market value of the LRT received at the block timestamp. The LRT begins a new Section 104 pool.

Unwrapping the LRT back to ETH — when withdrawal queues clear — is the reverse disposal. The pool average of the LRT is your cost basis; the GBP value of the ETH you receive is the proceeds.

Layer 2: AVS rewards are income at receipt

When the AVS (Actively Validated Service) layer distributes rewards in ETH, the protocol's native token, or a points-redeemable token, those are taxed as miscellaneous income at the GBP value at the moment of receipt. The receipt value also becomes the cost basis when you later dispose of those tokens. This is the same treatment as ordinary staking rewards under HMRC CRYPTO21250.

Layer 3: points are NOT yet taxable

Pure points balances — Ether.fi loyalty points, EigenLayer restaking points, Symbiotic points — are not chargeable until they are realised as a transferable asset. Until the points convert to a token that has a market price, no taxable event has occurred. The taxable event is the airdrop or claim, not the points accrual.

The airdrop event

When the protocol drops a token (for example, ETHFI to Ether.fi users), the value of the claim at the moment of receipt is miscellaneous income. If you claim and immediately sell, you have an income event followed by a CGT event with near-zero gain. If you claim and hold, the receipt value is your cost basis for the eventual disposal.

Common UK filer mistakes

Three mistakes we see repeatedly: treating the LRT wrap as not-a-disposal (it is, and it usually creates a small gain because the LRT trades at a premium to the spot ETH input); forgetting to report the airdrop claim event separately from the disposal; and trying to attach a GBP value to points balances mid-year. Points do not have a confirmed GBP value until the conversion event.

CryptoLens identifies LRT wraps, AVS reward streams, and airdrop claim events as three distinct row types, all with the correct GBP value at the block time of receipt.