Spain vs Hong Kong
Crypto regulation comparison
Spain
Hong Kong
Legal
Legal
Cryptocurrency is legal and increasingly regulated in Spain. Crypto capital gains are taxed at progressive savings tax rates (19-28%). Spain was an early mover in requiring crypto advertising to be pre-approved by the CNMV. Since 2024, Spanish taxpayers must report overseas crypto holdings via the Modelo 721 form. Banco de España registers VASPs for AML compliance. MiCA applies from December 2024.
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
Capital gains
Tax Type
No tax
Tax Rate
19-28%
Tax Rate
0%
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
CNMV (Comisión Nacional del Mercado de Valores), Banco de España
Regulator
SFC (Securities and Futures Commission), HKMA
Stablecoin Rules
Regulated under EU MiCA framework
Stablecoin Rules
HKMA developing a licensing regime for stablecoin issuers under a 2024 bill
Key Points
- Crypto gains taxed at savings rates: 19% (first €6,000), 21%, 23%, 27%, 28% (above €300,000)
- Modelo 721: mandatory declaration of overseas crypto holdings exceeding €50,000 (from 2024)
- CNMV requires pre-approval of crypto advertising targeting Spanish residents
- Banco de España maintains VASP registry for AML compliance
- Spain has a large crypto-using population; significant expat and digital nomad community
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