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Austria vs United Kingdom

Crypto regulation comparison

Austria

Austria

United Kingdom

United Kingdom

Legal
Legal

Cryptocurrency is legal in Austria and regulated under the EU's MiCA framework. Since March 2022, crypto assets are taxed at a flat 27.5% rate on capital gains, aligned with other investment income. The FMA supervises crypto service providers.

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').

Tax Type Capital gains
Tax Type Capital gains
Tax Rate 27.5%
Tax Rate 18-24%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator FMA (Finanzmarktaufsicht)
Regulator FCA (Financial Conduct Authority), HMRC, Bank of England
Stablecoin Rules Regulated under EU MiCA framework
Stablecoin Rules Stablecoin regulation under Financial Services and Markets Act 2023; fiat-backed stablecoins to be regulated by FCA
Key Points
  • Flat 27.5% tax on crypto capital gains since the 2022 eco-social tax reform
  • Crypto held before February 28, 2021 is subject to legacy rules (tax-free after 1 year)
  • FMA regulates VASPs under Austrian and EU law including MiCA
  • Exchanges must register and comply with AML/KYC obligations under FM-GwG
  • MiCA framework fully applicable from December 2024
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)