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United Kingdom vs Luxembourg

Crypto regulation comparison

← Back to map | United Kingdom | Luxembourg
United Kingdom

United Kingdom

Luxembourg

Luxembourg

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').

Luxembourg is a major European hub for crypto and blockchain financial services. The CSSF regulates VASPs and crypto-related investment funds. Crypto held for more than 6 months is generally exempt from capital gains tax for individuals, making it attractive for long-term holders. Luxembourg hosts several prominent crypto exchanges and fund administrators.

Tax Type Capital gains
Tax Type Capital gains
Tax Rate 18-24%
Tax Rate 0-42%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator FCA (Financial Conduct Authority), HMRC, Bank of England
Regulator CSSF (Commission de Surveillance du Secteur Financier)
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; Luxembourg hosts major stablecoin issuers
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
  • CSSF oversees VASPs under the Luxembourg AML/CFT framework
  • Individuals holding crypto for 6+ months are generally exempt from capital gains tax
  • Short-term gains taxed at progressive income tax rates up to 42%
  • Major hub for crypto investment funds and blockchain companies
  • MiCA framework fully applicable from December 2024
Sources
Sources