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United Kingdom vs Italy

Crypto regulation comparison

United Kingdom

United Kingdom

Italy

Italy

Legal
Legal

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 Italy with a 26% capital gains tax on crypto profits exceeding €2,000 per year. VASPs must register with the OAM (Agents and Mediators Register). Italy was one of the first EU countries to require VASP registration and has aligned with MiCA.

Tax Type Capital gains
Tax Type Capital gains
Tax Rate 18-24%
Tax Rate 26%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator FCA (Financial Conduct Authority), HMRC, Bank of England
Regulator OAM (Organismo Agenti e Mediatori), Consob, Banca d'Italia
Stablecoin Rules Stablecoin regulation under Financial Services and Markets Act 2023; fiat-backed stablecoins to be regulated by FCA
Stablecoin Rules Regulated under EU MiCA framework
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
  • 26% substitute tax on crypto capital gains exceeding €2,000 per year (since 2023 budget law)
  • Italian government proposed raising crypto tax to 42% for 2025 but this was reduced back to 26%
  • VASPs must register with OAM and comply with AML requirements
  • Crypto holdings above €51,645.69 were previously the threshold; new regime simplified this
  • MiCA framework applicable from December 2024