The four regimes at a glance
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| Question | United States | United Kingdom | UAE (VARA / ADGM) | For comparison: Switzerland / Singapore |
|---|---|---|---|---|
| Statutory regime for service providers | State and federal registration; CLARITY Act pending | FSMA 2000 (Cryptoassets) Regulations 2026; live 25 October 2027 | VARA Regulations 2023; FSRA framework 2018 | DLT Act / FINMA; PSA, SFA, FSMA |
| Stablecoin regime | GENIUS Act, in force by January 2027 | Qualifying stablecoin issuance (FCA); systemic regime (Bank of England) | CBUAE Payment Token Services Regulation (dirham only for payments) | FINMA deposit characterisation; MAS SCS framework |
| Retail access | Permitted through registered intermediaries | Permitted with financial-promotion rules | Permitted (VARA) | Permitted (both) |
| Overseas firm serving retail | Prohibited without registration | Prohibited without authorisation from October 2027 | Prohibited without licence | Permitted into Switzerland; Singapore base captured |
| Property status | Property for tax; state law varies (UCC Article 12) | Third category by statute (2025) | DIFC Digital Assets Law 2024 | Factual power of disposal; thing in action (ByBit) |
| Capital gains tax on individuals | Yes | Yes, 18 % / 24 % | None | None (private) / none |
| Corporate tax | 21 % federal plus state | 25 % | 9 %; 0 % qualifying free zone | 12–20 % / 17 % |
| CARF | Committed; no implementing rules | From 1 January 2026 | From 2028 | Switzerland: data collection from 2027 at the earliest, first exchange 2028; Singapore: first exchanges 2027 or 2028 (see Chapter V) |
| Protocol vehicle | Wyoming DAO LLC; Delaware | Limited by guarantee; no foundation | ADGM DLT Foundation | Zug foundation / Singapore CLG |
Practice note
When a client asks about one of these three jurisdictions, resist the urge to compare regimes and ask what the client wants from it. Capital means the United States and a Regulation D or S structure, no licence. Customers means a local subsidiary and licence in any of the three, with two to three years of lead time in the United States and the United Kingdom and under a year in Dubai. Court protection means London. Zero tax and a licence quickly means Dubai with real presence. Nothing in this chapter changes the Zug or Singapore base. It changes what the base needs to add.
For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.