United Kingdom vs Philippines
Crypto regulation comparison
United Kingdom
Philippines
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').
The Philippines is one of the largest crypto markets in Southeast Asia. The BSP licenses Virtual Asset Service Providers (VASPs) under Circular 1108 (2021), and the SEC regulates crypto as securities where applicable. The Philippines saw massive adoption through play-to-earn games (Axie Infinity) and remittances. Crypto income is taxed at progressive income tax rates.
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
- BSP Circular 1108 (2021) provides comprehensive VASP licensing framework
- BSP has licensed major exchanges including Coins.ph and PDAX
- SEC Philippines regulates crypto securities and has issued warnings on unregistered offerings
- Crypto income taxed at progressive rates (0-35%); 12% VAT may apply to exchanges
- Play-to-earn gaming (Axie Infinity) drove massive adoption, especially in rural areas
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)