United Arab Emirates vs Hong Kong
Crypto regulation comparison
United Arab Emirates
Hong Kong
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.
Hong Kong has positioned itself as a major crypto hub in Asia with a comprehensive licensing regime. The SFC implemented a mandatory licensing framework for virtual asset trading platforms (VATPs) effective June 2023. Hong Kong has no capital gains tax, making it attractive for crypto investors and businesses.
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
- Mandatory VATP licensing regime under the AMLO effective June 1, 2023
- No capital gains tax in Hong Kong; profits tax applies only to business profits
- SFC approved spot Bitcoin and Ether ETFs for retail investors in April 2024
- HKMA consulting on stablecoin issuer licensing under a dedicated bill
- Hong Kong actively competes with Singapore as Asia's leading crypto hub