Australia vs Hong Kong
Crypto regulation comparison
Australia
Hong Kong
Legal
Legal
Cryptocurrency is legal and well-regulated in Australia. AUSTRAC oversees AML/CTF compliance for exchanges, ASIC handles consumer protection, and the ATO treats crypto as property for tax purposes. Australia has been developing a comprehensive licensing framework for digital asset platforms.
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.
Tax Type
Capital gains
Tax Type
No tax
Tax Rate
0-45%
Tax Rate
0%
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
ASIC, AUSTRAC, ATO
Regulator
SFC (Securities and Futures Commission), HKMA
Stablecoin Rules
Stablecoins to be regulated under proposed payments framework legislation
Stablecoin Rules
HKMA developing a licensing regime for stablecoin issuers under a 2024 bill
Key Points
- Digital currency exchanges must register with AUSTRAC and comply with AML/CTF Act
- ATO treats cryptocurrency as a CGT asset; holding for 12+ months qualifies for 50% discount
- ASIC regulates crypto products that qualify as financial products under the Corporations Act
- Treasury released a token mapping consultation in 2023 to classify digital assets
- Proposed licensing regime for digital asset platforms under development
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