United Kingdom vs Thailand
Crypto regulation comparison
United Kingdom
Thailand
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').
Thailand has a comprehensive crypto regulatory framework under the Digital Asset Business Emergency Decree (2018). The SEC Thailand licenses digital asset exchanges, brokers, and dealers. Crypto gains are taxed at 15% withholding tax, though the government exempted VAT on crypto trading on authorized exchanges from 2022. Thailand has a well-developed exchange ecosystem with Bitkub as the dominant platform.
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
- Digital Asset Business Emergency Decree B.E. 2561 (2018) provides comprehensive regulation
- SEC Thailand licenses exchanges, brokers, dealers, and fund managers for digital assets
- 15% withholding tax on crypto gains; VAT exempted on authorized exchange trades since 2022
- BOT restricts crypto for payments but allows it as an investment asset
- Bitkub is the dominant exchange (~90% market share domestically)
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)