This table puts the main rules of our ten country guides side by side. It is a starting point: each country has its own page with the details, the exceptions and the official sources. Amounts are in the local currency and apply to the year shown.
The comparison
| Country | Private gains (individuals) | Company tax (headline rate) | Who licenses providers | Tax reporting by providers |
|---|---|---|---|---|
| Australia | Capital gains tax. Residents can reduce a gain by 50% after 12 months. A personal use asset that cost AUD 10,000 or less is exempt. | 25% for base rate entities, 30% for others (2025-26) | ASIC (financial products) and AUSTRAC (registration) | Proposed from 1 January 2027, first exchange expected in 2028 |
| Canada | Capital gain (half is taxable) or business income, depending on the facts | Federal 15%, or 9% for qualifying small businesses, plus provincial tax | Provincial securities regulators and FINTRAC | Draft law for 2026 onward, first returns before 2 May 2027 |
| Germany | Taxable if sold within one year, with a €1,000 limit. A reform draft was published on 30 September 2026. | Corporate tax 15% in 2026, falling to 10% from 2032, plus surcharge and trade tax | BaFin | From 2026, first report due 31 July 2027 |
| Netherlands | Box 3: an assumed return of 6.00% taxed at 36%, after a €59,357 allowance (2026) | 19.0% up to €200,000, 25.8% above (2026) | AFM (license), DNB (prudential) | From 1 January 2026, first report due by 31 January 2027 |
| Portugal | Excluded from tax after 365 days, 28% before that (check for changes in 2026) | 19% in 2026, and 15% on the first €50,000 for qualifying small companies | Banco de Portugal and CMVM | From 1 January 2026, first report due 31 May 2027 |
| Singapore | Generally viewed as personal investments. Taxable if it amounts to trading, depending on the facts. | 17% flat, with partial exemptions | MAS | Exchanges planned from September 2028 |
| Switzerland | Private gains are tax-free at the federal level. Crypto counts as taxable wealth. | Federal, cantonal and communal profit tax (see the country page) | FINMA | Earliest 1 January 2027 |
| United Arab Emirates | No official statement found. Corporate tax applies to an individual only above AED 1 million of business turnover. | 0% up to AED 375,000, 9% above | VARA (Dubai), FSRA (ADGM), SCA (elsewhere) | First exchanges expected in 2028 |
| United Kingdom | Capital Gains Tax at 18% or 24%, with a £3,000 annual exempt amount (2026/27) | 19% to 25%, depending on profits (financial year 2026) | FCA | In force since 1 January 2026, reports by 31 May |
| United States | Treated as property. Long-term gains are taxed at 0%, 15% or 20%, short-term gains as ordinary income. | 21% federal | FinCEN (registration), SEC and CFTC | Brokers report on Form 1099-DA from 2025 sales |
How to read this table
- Headline rates leave things out. Brackets, allowances, local taxes and special cases differ by country. The country pages explain them.
- “No official statement found” means that we did not find an answer in the official sources we could read. It does not mean there is no rule.
- Dates change. Several countries have laws or reforms that are still going through parliament. The country pages say what stage they have reached.
- EU members share some rules. The Netherlands, Germany and Portugal apply the same EU licensing and reporting laws. See EU rules: MiCA, DAC8 and the travel rule.
Sources
Every figure in the table comes from the official sources listed on that country’s page.
- Australia: sources (last checked October 2026)
- Canada: sources (last checked October 2026)
- Germany: sources (last checked October 2026)
- Netherlands: sources (last checked October 2026)
- Portugal: sources (last checked October 2026)
- Singapore: sources (last checked October 2026)
- Switzerland: sources (last checked October 2026)
- United Arab Emirates: sources (last checked October 2026)
- United Kingdom: sources (last checked October 2026)
- United States: sources (last checked October 2026)
This page is general information, not legal or tax advice. Rules and rates change, so check the official sources before you act.