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Bahamas vs Hong Kong

Crypto regulation comparison

Bahamas

Bahamas

Hong Kong

Hong Kong

Legal
Legal

The Bahamas enacted the Digital Assets and Registered Exchanges (DARE) Act in 2020, creating a comprehensive regulatory framework. The SCB oversees digital asset businesses. The Bahamas also launched the Sand Dollar CBDC.

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 No tax
Tax Type No tax
Tax Rate 0%
Tax Rate 0%
Exchanges Yes Yes
Exchanges Yes Yes
Mining No No
Mining Yes Yes
Regulator Securities Commission of the Bahamas (SCB)
Regulator SFC (Securities and Futures Commission), HKMA
Stablecoin Rules Regulated under DARE Act 2024; algorithmic stablecoins banned
Stablecoin Rules HKMA developing a licensing regime for stablecoin issuers under a 2024 bill
Key Points
  • DARE Act (2020) provides comprehensive regulation for digital assets and exchanges
  • Securities Commission of the Bahamas licenses and supervises digital asset businesses
  • No income tax, capital gains tax, or crypto-specific taxes
  • Sand Dollar CBDC launched in 2020 as one of the world's first
  • FTX collapse in 2022 led to enhanced scrutiny and regulatory updates
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