Belgium vs United Kingdom

Cryptocurrency is legal in Belgium and regulated under the EU's MiCA framework. Tax treatment depends on whether gains are considered normal management of private assets (tax-free), speculative (33% misc income), or professional income (progressive rates). The FSMA has banned distribution of crypto derivatives to consumers.

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').