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Hong Kong vs Kyrgyzstan

Crypto regulation comparison

Hong Kong

Hong Kong

Kyrgyzstan

Kyrgyzstan

Legal
Legal

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.

Kyrgyzstan adopted the Law on Virtual Assets in 2022 requiring licensing for exchanges, mining, and VASPs. Over 120 licensed VASPs operate. Crypto turnover exceeded traditional securities market in 2024.

Tax Type No tax
Tax Type Income
Tax Rate 0%
Tax Rate 10%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator SFC (Securities and Futures Commission), HKMA
Regulator State Financial Supervision Authority
Stablecoin Rules HKMA developing a licensing regime for stablecoin issuers under a 2024 bill
Stablecoin Rules Regulated under Virtual Assets Law
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
  • Law on Virtual Assets adopted in 2022 with licensing framework
  • Over 120 licensed VASPs active by late 2024
  • Three license types: trading operator, currency exchanger, mining operator
  • Crypto sector contributed 800M KGS in taxes in 2024
  • Virtual assets not recognized as legal tender but circulate under special regime