Hong Kong vs Panama
Crypto regulation comparison
Hong Kong
Panama
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.
Panama passed Law 129 in 2024 regulating crypto assets, virtual asset service providers, and tokenized securities. Panama has no capital gains tax on foreign-sourced or investment income, making it attractive for crypto investors. The law provides a regulatory framework for exchanges and establishes AML/KYC obligations for VASPs.
Tax Type
No tax
Tax Type
None
Tax Rate
0%
Tax Rate
0%
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
SFC (Securities and Futures Commission), HKMA
Regulator
SBP (Superintendencia de Bancos de Panamá), SMV
Stablecoin Rules
HKMA developing a licensing regime for stablecoin issuers under a 2024 bill
Stablecoin Rules
No specific stablecoin regulation
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 129 (2024) regulates crypto assets and VASPs in Panama
- No capital gains tax on investment or foreign-sourced income (territorial tax system)
- VASPs must comply with AML/KYC requirements under the new framework
- Crypto payments for commercial transactions are permitted
- Panama's territorial tax system means crypto gains from international trading are untaxed