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Bulgaria vs United Kingdom

Crypto regulation comparison

Bulgaria

Bulgaria

United Kingdom

United Kingdom

Legal
Legal

Cryptocurrency is legal in Bulgaria and subject to a flat 10% tax on capital gains, one of the lowest in the EU. Bulgaria adopted the EU's MiCA framework and requires crypto service providers to register. The country has a notable history with crypto due to a large government Bitcoin seizure in 2017.

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 10%
Tax Rate 18-24%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator NRA (National Revenue Agency), FSC (Financial Supervision Commission)
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 10% personal income tax rate applies to crypto capital gains
  • VASPs must register with the NRA for AML compliance
  • MiCA framework applicable from December 2024
  • Bulgaria reportedly seized approximately 200,000 BTC in a 2017 crime bust (status debated)
  • No specific crypto legislation beyond EU directives and general tax law
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)