Germany vs United Kingdom

Germany has one of the most well-defined crypto regulatory environments in Europe. BaFin has regulated crypto custody as a financial service since 2020. Notably, crypto held for over one year by individuals is completely tax-free, making Germany one of the most favorable jurisdictions for long-term holders.

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').