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United Kingdom vs Panama

Crypto regulation comparison

United Kingdom

United Kingdom

Panama

Panama

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').

Panama passed Law 129 in 2024 regulating crypto assets, virtual asset service providers, and tokenized securities. Panama has no capital gains tax on foreign-sourced or investment income, making it attractive for crypto investors. The law provides a regulatory framework for exchanges and establishes AML/KYC obligations for VASPs.

Tax Type Capital gains
Tax Type None
Tax Rate 18-24%
Tax Rate 0%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator FCA (Financial Conduct Authority), HMRC, Bank of England
Regulator SBP (Superintendencia de Bancos de Panamá), SMV
Stablecoin Rules Stablecoin regulation under Financial Services and Markets Act 2023; fiat-backed stablecoins to be regulated by FCA
Stablecoin Rules No specific stablecoin regulation
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
  • Law 129 (2024) regulates crypto assets and VASPs in Panama
  • No capital gains tax on investment or foreign-sourced income (territorial tax system)
  • VASPs must comply with AML/KYC requirements under the new framework
  • Crypto payments for commercial transactions are permitted
  • Panama's territorial tax system means crypto gains from international trading are untaxed