United Kingdom vs Norway
Crypto regulation comparison
United Kingdom
Norway
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 Norway and regulated by Finanstilsynet. Norway taxes crypto capital gains at 22% and includes crypto holdings in the annual wealth tax calculation (net wealth above NOK 1.7M taxed at ~1.1%). VASPs must register with Finanstilsynet. Norway is an EEA member and aligning with MiCA through the EEA agreement.
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
- Crypto capital gains taxed at 22% flat rate
- Crypto included in wealth tax base (~1.1% on net wealth above threshold)
- VASPs must register with Finanstilsynet and comply with AML/CFT requirements
- Norway is a major crypto mining hub due to cheap hydroelectric power
- EEA member; MiCA implementation expected through EEA Agreement adaptation
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)