Hong Kong has no separate crypto tax and no digital-asset provisions in the Inland Revenue Ordinance. Profits from digital assets fall within profits tax under the ordinary machinery of section 14 of Cap. 112 where they are trading profits with a Hong Kong source; capital gains are not taxed at all. The only Inland Revenue Department guidance on the substance is DIPN 39 (Revised) of March 2020, which has not been updated since. The practical consequence is that everything turns on the line between trading stock and a capital asset, and that line is drawn by the intention at acquisition and by nine questions set out by the Court of Final Appeal.