Cyprus vs United Kingdom
Crypto regulation comparison
Cyprus
United Kingdom
Cyprus regulates crypto under the EU MiCA framework (fully applicable since December 2024). CySEC authorizes crypto-asset service providers (CASPs) while the Central Bank of Cyprus oversees e-money tokens and asset-referenced tokens. Crypto gains from occasional transactions are currently not taxed; active trading is taxed as income at 0-35%. A proposed 8% flat tax on crypto gains is pending parliamentary approval for 2026.
The UK has an evolving and increasingly comprehensive crypto regulatory framework. The FCA registers crypto firms for AML/CFT compliance and has imposed strict financial promotion rules requiring risk warnings and banning incentives. HMRC treats crypto as property subject to Capital Gains Tax (10% basic rate, 20% higher rate, with £3,000 annual exemption from 2024/25). The Financial Services and Markets Act 2023 brought crypto assets into the UK regulatory perimeter, and HM Treasury is developing rules for a full crypto regime including exchange licensing, stablecoin regulation, and a potential UK CBDC ('Britcoin').
Key Points
- CySEC authorizes and supervises crypto-asset service providers under MiCA
- No capital gains tax on crypto for occasional transactions; active trading taxed as income
- EU MiCA regulation applies as an EU member state
- AML/CFT requirements enforced for all crypto businesses
- Proposed 8% flat tax on crypto gains pending parliamentary approval for 2026
Key Points
- FCA AML registration required for all crypto firms operating in the UK
- Capital Gains Tax: 10% (basic rate) or 20% (higher rate); £3,000 annual exempt amount (2024/25)
- Financial promotions regime (2023): strict rules on crypto advertising, risk warnings mandatory
- Financial Services and Markets Act 2023 brings crypto into regulatory perimeter
- HM Treasury developing comprehensive crypto regulatory regime (exchange licensing, conduct rules)
Sources
- HMRC - Cryptoassets Manual
- FCA - Cryptoassets Information
- HMRC - Capital Gains Tax Rates
- HMRC - Cryptoassets Manual: Mining
- FCA - Regulation of Digital Assets Speech
- FCA - Cryptoasset Registration Application
- FCA - Regulating Cryptoasset Activities (DP25/1)
- FCA - Financial Promotion Rules for Cryptoassets (PS23/6)