United Arab Emirates vs United Kingdom
Crypto regulation comparison
United Arab Emirates
United Kingdom
The UAE has become a global crypto hub with multiple regulatory frameworks. Dubai's VARA (Virtual Assets Regulatory Authority), established in 2022, is the world's first dedicated crypto regulator and licenses exchanges, brokers, and other VASPs. Abu Dhabi's ADGM regulates crypto through the FSRA. The federal SCA also oversees crypto at the national level. The UAE has no personal income or capital gains tax. Major global exchanges (Binance, Bybit, OKX, Crypto.com) have obtained UAE licenses.
The UK has an evolving and increasingly comprehensive crypto regulatory framework. The FCA registers crypto firms for AML/CFT compliance and has imposed strict financial promotion rules requiring risk warnings and banning incentives. HMRC treats crypto as property subject to Capital Gains Tax (10% basic rate, 20% higher rate, with £3,000 annual exemption from 2024/25). The Financial Services and Markets Act 2023 brought crypto assets into the UK regulatory perimeter, and HM Treasury is developing rules for a full crypto regime including exchange licensing, stablecoin regulation, and a potential UK CBDC ('Britcoin').
Key Points
- VARA (Dubai) — world's first standalone virtual asset regulator; comprehensive licensing framework
- ADGM/FSRA (Abu Dhabi) — separate regulatory framework for digital assets in the financial free zone
- No personal income tax or capital gains tax in the UAE
- 9% corporate tax (from 2023) may apply to crypto businesses but not individual investors
- Major exchanges licensed: Binance, Bybit, OKX, Crypto.com, BitOasis
Key Points
- FCA AML registration required for all crypto firms operating in the UK
- Capital Gains Tax: 10% (basic rate) or 20% (higher rate); £3,000 annual exempt amount (2024/25)
- Financial promotions regime (2023): strict rules on crypto advertising, risk warnings mandatory
- Financial Services and Markets Act 2023 brings crypto into regulatory perimeter
- HM Treasury developing comprehensive crypto regulatory regime (exchange licensing, conduct rules)
Sources
Sources
- HMRC - Cryptoassets Manual
- FCA - Cryptoassets Information
- HMRC - Capital Gains Tax Rates
- HMRC - Cryptoassets Manual: Mining
- FCA - Regulation of Digital Assets Speech
- FCA - Cryptoasset Registration Application
- FCA - Regulating Cryptoasset Activities (DP25/1)
- FCA - Financial Promotion Rules for Cryptoassets (PS23/6)