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Canada vs Hong Kong

Crypto regulation comparison

Canada

Canada

Hong Kong

Hong Kong

Legal
Legal

Canada has a well-developed regulatory framework for cryptocurrency. Crypto trading platforms must register with provincial securities regulators through the CSA, and all crypto businesses must register as money services businesses (MSBs) with FINTRAC. Canada approved spot Bitcoin ETFs in 2021, ahead of most other countries.

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 0-26.76%
Tax Rate 0%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator CSA, FINTRAC, OSC, AMF
Regulator SFC (Securities and Futures Commission), HKMA
Stablecoin Rules CSA guidance requires stablecoins to maintain adequate reserves; value-referenced crypto assets regulated
Stablecoin Rules HKMA developing a licensing regime for stablecoin issuers under a 2024 bill
Key Points
  • Crypto trading platforms must register with CSA provincial regulators
  • All crypto dealers must register as MSBs with FINTRAC for AML/KYC compliance
  • 50% of capital gains are taxable; business income from crypto is fully taxable
  • Canada approved spot Bitcoin and Ether ETFs in 2021, the first major country to do so
  • CSA issued Staff Notice 21-327 on obligations for crypto trading platforms
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