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Switzerland vs Hong Kong

Crypto regulation comparison

← Back to map | Switzerland | Hong Kong
Switzerland

Switzerland

Hong Kong

Hong Kong

Legal
Legal

Switzerland is one of the world's most crypto-friendly jurisdictions. The Canton of Zug is known as 'Crypto Valley' and hosts the Ethereum Foundation and hundreds of blockchain companies. FINMA provides clear regulatory guidance, and the DLT Act (2021) created a legal framework for tokenized securities and crypto exchanges. Individual investors pay no capital gains tax on crypto, though it is included in the cantonal wealth tax base. Professional traders may be subject to income tax.

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 Wealth
Tax Type No tax
Tax Rate 0% capital gains (individuals); wealth tax varies by canton
Tax Rate 0%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator FINMA (Swiss Financial Market Supervisory Authority)
Regulator SFC (Securities and Futures Commission), HKMA
Stablecoin Rules Regulated under FINMA framework; fiat-pegged stablecoin issuers must hold a banking or fintech licence (reserves treated as public deposits), or a payment system licence under FMIA if structured as financial market infrastructure
Stablecoin Rules HKMA developing a licensing regime for stablecoin issuers under a 2024 bill
Key Points
  • No capital gains tax on crypto for individual investors (private wealth management)
  • Crypto included in cantonal wealth tax base (rates vary by canton, typically 0.1-1%)
  • Professional/frequent traders may be classified as self-employed and taxed on income
  • FINMA regulates crypto under existing financial market laws and the 2021 DLT Act
  • DLT Act (2021) introduced DLT trading facility license and legal framework for tokenized assets
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
Sources
Sources