Cyprus vs Hong Kong
Crypto regulation comparison
Cyprus
Hong Kong
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.
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.
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
- 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