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Hong Kong vs South Korea

Crypto regulation comparison

Hong Kong

Hong Kong

South Korea

South Korea

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.

South Korea is one of the world's largest crypto markets. The Virtual Asset Users Protection Act (VAUPA), effective July 2024, provides comprehensive investor protection including requirements for exchanges to hold user assets in cold storage and carry insurance. All VASPs must register with FIU and comply with strict AML rules under the Specific Financial Information Act. A 20% crypto gains tax (above KRW 2.5 million exemption, raised from the original 250K KRW threshold) has been deferred multiple times and is now scheduled for January 2027.

Tax Type No tax
Tax Type Varies
Tax Rate 0%
Tax Rate 20%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator SFC (Securities and Futures Commission), HKMA
Regulator FSC (Financial Services Commission), FSS, FIU (Korea Financial Intelligence Unit)
Stablecoin Rules HKMA developing a licensing regime for stablecoin issuers under a 2024 bill
Stablecoin Rules Under development; stablecoins subject to VASP rules
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
  • Virtual Asset Users Protection Act (VAUPA) effective July 2024 — major investor protection law
  • VASPs must register with FIU and partner with real-name verified bank accounts
  • 20% national tax (22% effective incl. 2% local income surtax) above KRW 2.5M annual exemption (deferred to January 2027)
  • Exchanges must hold 80%+ of user assets in cold wallets and carry insurance/reserves
  • Only won-denominated trading pairs allowed on major exchanges (Upbit, Bithumb, Coinone, Korbit)