United Kingdom vs Ireland
Crypto regulation comparison
United Kingdom
Ireland
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').
Cryptocurrency is legal in Ireland and subject to a 33% capital gains tax, one of the higher rates in the EU. The Central Bank of Ireland supervises VASPs under AML regulations, and Ireland follows the EU's MiCA framework. Ireland's status as a European tech hub has attracted crypto businesses.
Key Points
- FCA AML registration required for all crypto firms operating in the UK
- Capital Gains Tax: 10% (basic rate) or 20% (higher rate); £3,000 annual exempt amount (2024/25)
- Financial promotions regime (2023): strict rules on crypto advertising, risk warnings mandatory
- Financial Services and Markets Act 2023 brings crypto into regulatory perimeter
- HM Treasury developing comprehensive crypto regulatory regime (exchange licensing, conduct rules)
Key Points
- 33% capital gains tax on crypto profits (CGT), with an annual exemption of €1,270
- Income from crypto mining, staking, or airdrops may be treated as income tax
- Central Bank of Ireland registers VASPs under the Criminal Justice (Money Laundering) Act
- MiCA framework applicable from December 2024
- Ireland hosts European headquarters of several major crypto firms
Sources
- HMRC - Cryptoassets Manual
- FCA - Cryptoassets Information
- HMRC - Capital Gains Tax Rates
- HMRC - Cryptoassets Manual: Mining
- FCA - Regulation of Digital Assets Speech
- FCA - Cryptoasset Registration Application
- FCA - Regulating Cryptoasset Activities (DP25/1)
- FCA - Financial Promotion Rules for Cryptoassets (PS23/6)