Denmark vs Hong Kong
Crypto regulation comparison
Denmark
Hong Kong
Cryptocurrency is legal in Denmark and regulated under EU frameworks including MiCA. Denmark has notably high tax rates on crypto gains, treated as personal income and taxed at rates up to 52%. The Danish Tax Council confirmed in 2018 that gains and losses on Bitcoin are taxable.
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
- Crypto gains taxed as personal income at 37-52% (among the highest in the world)
- Losses on crypto can be deducted against gains
- Finanstilsynet supervises crypto businesses under the Danish AML Act
- Denmark does not have its own crypto-specific legislation beyond EU frameworks
- Skattestyrelsen (tax authority) actively monitors crypto transactions and issues guidance
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