Hong Kong vs Poland
Crypto regulation comparison
Hong Kong
Poland
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 and regulated in Poland. Crypto capital gains are taxed at a flat 19% rate. The KNF (Polish Financial Supervision Authority) oversees crypto-related financial services, and VASPs must register for AML compliance. Poland has a growing crypto community and several domestic exchanges. MiCA applies from December 2024.
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
- Flat 19% tax on crypto capital gains (PIT-38 annual declaration)
- Crypto-to-crypto transactions are not taxable events; only fiat conversions trigger tax
- VASPs must register in the AML register maintained by the Tax Administration Chamber
- KNF oversees market conduct and consumer protection for crypto services
- MiCA framework applicable from December 2024