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Brazil vs Hong Kong

Crypto regulation comparison

Brazil

Brazil

Hong Kong

Hong Kong

Legal
Legal

Brazil passed comprehensive crypto legislation (Law 14,478) in December 2022, which took effect in June 2023. The Banco Central do Brasil was designated as the primary regulator for crypto assets used as payment, while the CVM oversees crypto securities. Capital gains on crypto are taxed at 15-22.5%.

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 15-22.5%
Tax Rate 0%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator Banco Central do Brasil, CVM, Receita Federal
Regulator SFC (Securities and Futures Commission), HKMA
Stablecoin Rules Central Bank developing stablecoin-specific rules as part of the crypto regulatory framework
Stablecoin Rules HKMA developing a licensing regime for stablecoin issuers under a 2024 bill
Key Points
  • Law 14,478/2022 (Marco Legal das Criptomoedas) provides a comprehensive legal framework
  • Banco Central regulates VASPs; exchanges must obtain authorization to operate
  • Capital gains taxed at 15% (up to R$5M), 17.5% (R$5-10M), 20% (R$10-30M), 22.5% (above R$30M)
  • Monthly gains under R$35,000 from sales on domestic exchanges are exempt
  • Receita Federal requires detailed monthly reporting of crypto transactions via IN1888
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