I think this is something people should be discussing more. There are a couple of things I don't understand

From the HMRC brief:

"Whether any profit or gain is chargeable or any loss is allowable will be looked at on a case-by-case basis taking into account the specific facts. Each case will be considered on the basis of its own individual facts and circumstances. The relevant legislation and case law will be applied to determine the correct tax treatment. Therefore, depending on the facts, a transaction may be so highly speculative that it is not taxable or any losses relievable."

Question: What constitutes "so highly speculative"? Is an ICO investment so highly speculative that it is not taxable?

Also from the HMRC brief:

"Chargeable gains: CT and CGT - if a profit or loss on a currency contract is not within trading profits or otherwise within the loan relationship rules, it would normally be taxable as a chargeable gain or allowable as a loss for CT or CGT purposes. Gains and losses incurred on Bitcoin or other cryptocurrencies are chargeable or allowable for CGT if they accrue to an individual or, for CT on chargeable gains if they accrue to a company."

What does "within trading profits or otherwise within the loan relationship rules" mean?

Thanks