RWA跟踪系列：多路径下RWA政策研究框架

Regulatory Framework - RWA policies are evaluated across six dimensions: ownership mechanism, circulation restrictions, licensing thresholds, tax environment, stablecoin adaptation, and asset structure compliance[11] - The regulatory intensity varies significantly, with some regions emphasizing strong regulation and safety, while others focus on innovation and pilot programs[16] Global Comparisons - The United States, United Kingdom, and Japan maintain high regulatory barriers, reflecting a "strong regulation, safety first" approach, with scores indicating high institutional density and limited innovation space[17] - In contrast, Singapore, UAE, and South Korea adopt a "innovation-oriented, pilot-first" strategy, lowering entry barriers and fostering a flexible regulatory environment[17] Taxation and Incentives - Tax policies are becoming a critical variable, with regions like the EU and South Korea having higher tax burdens but stronger regulatory frameworks, while Singapore and UAE attract projects with low tax rates and flexible regulations[24] - The EU has not established a unified income tax law for crypto assets, leading to structural inconsistencies across member states, impacting the attractiveness of RWA development[36] Regional Practices - The EU employs a standardized regulatory approach through MiCA, ensuring cross-border operational predictability and compliance for RWA assets[32] - South Korea has significantly lowered entry barriers for RWA and stablecoin issuance, promoting rapid market growth and innovation[38] Hong Kong's Unique Position - Hong Kong combines strict licensing with low tax burdens, establishing a regulatory model that supports RWA development while ensuring investor protection[42] - The region's legal system recognizes virtual assets as property, facilitating the establishment of a compliant RWA ecosystem[47] China's Regulatory Stance - China currently restricts RWA to "on-chain registration, off-chain issuance," limiting the operational scope for digital assets within its jurisdiction[48] - The country emphasizes technological service over financial attributes in its asset digitization efforts, focusing on traceability rather than market circulation[49]