United Kingdom vs New Zealand

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 New Zealand and treated as a form of property for tax purposes. The IRD taxes crypto depending on the purpose of acquisition — if bought with the intention to sell, gains are taxable income. New Zealand does not have a formal capital gains tax, but crypto profits are often taxable under income tax rules. Exchanges are not specifically licensed but must comply with AML/CFT requirements.