United Kingdom vs Portugal

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').

Portugal was formerly a crypto tax haven with 0% capital gains tax on crypto for individuals, but the 2023 State Budget introduced a 28% capital gains tax on crypto held for less than one year. Crypto held for over 365 days remains tax-free for individuals. Banco de Portugal registers VASPs for AML compliance, and Portugal transitions to MiCA. Portugal attracted many crypto entrepreneurs due to its previously favorable tax regime and NHR (Non-Habitual Resident) program.