Hong Kong vs Ireland
Crypto regulation comparison
Hong Kong
Ireland
Hong Kong has positioned itself as a major crypto hub in Asia with a comprehensive licensing regime. The SFC implemented a mandatory licensing framework for virtual asset trading platforms (VATPs) effective June 2023. Hong Kong has no capital gains tax, making it attractive for crypto investors and businesses.
Cryptocurrency is legal in Ireland and subject to a 33% capital gains tax, one of the higher rates in the EU. The Central Bank of Ireland supervises VASPs under AML regulations, and Ireland follows the EU's MiCA framework. Ireland's status as a European tech hub has attracted crypto businesses.
Key Points
- Mandatory VATP licensing regime under the AMLO effective June 1, 2023
- No capital gains tax in Hong Kong; profits tax applies only to business profits
- SFC approved spot Bitcoin and Ether ETFs for retail investors in April 2024
- HKMA consulting on stablecoin issuer licensing under a dedicated bill
- Hong Kong actively competes with Singapore as Asia's leading crypto hub
Key Points
- 33% capital gains tax on crypto profits (CGT), with an annual exemption of €1,270
- Income from crypto mining, staking, or airdrops may be treated as income tax
- Central Bank of Ireland registers VASPs under the Criminal Justice (Money Laundering) Act
- MiCA framework applicable from December 2024
- Ireland hosts European headquarters of several major crypto firms