Bulgaria vs Hong Kong
Crypto regulation comparison
Bulgaria
Hong Kong
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.
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
10%
Tax Rate
0%
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
NRA (National Revenue Agency), FSC (Financial Supervision Commission)
Regulator
SFC (Securities and Futures Commission), HKMA
Stablecoin Rules
Regulated under EU MiCA framework
Stablecoin Rules
HKMA developing a licensing regime for stablecoin issuers under a 2024 bill
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
- 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