France vs Hong Kong
Crypto regulation comparison
France
Hong Kong
Legal
Legal
France has one of Europe's most developed crypto regulatory frameworks. The PACTE law (2019) established the PSAN (prestataire de services sur actifs numériques) registration regime, now transitioning to MiCA licensing. Crypto gains are subject to the 30% flat tax (prélèvement forfaitaire unique).
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
30%
Tax Rate
0%
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
AMF (Autorité des Marchés Financiers), ACPR
Regulator
SFC (Securities and Futures Commission), HKMA
Stablecoin Rules
Regulated under MiCA; stablecoin issuers need e-money or credit institution license
Stablecoin Rules
HKMA developing a licensing regime for stablecoin issuers under a 2024 bill
Key Points
- 30% flat tax on crypto capital gains (12.8% income tax + 17.2% social charges) for non-professionals
- PSAN registration required by AMF for all crypto service providers (mandatory since 2023)
- Transitioning from PSAN regime to MiCA licensing framework in 2024-2025
- Professional crypto traders may opt for progressive income tax rates
- France is home to major crypto companies including Ledger and Société Générale's FORGE
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