United Arab Emirates vs Estonia
Crypto regulation comparison
United Arab Emirates
Estonia
The UAE has become a global crypto hub with multiple regulatory frameworks. Dubai's VARA (Virtual Assets Regulatory Authority), established in 2022, is the world's first dedicated crypto regulator and licenses exchanges, brokers, and other VASPs. Abu Dhabi's ADGM regulates crypto through the FSRA. The federal SCA also oversees crypto at the national level. The UAE has no personal income or capital gains tax. Major global exchanges (Binance, Bybit, OKX, Crypto.com) have obtained UAE licenses.
Estonia was an early mover in crypto regulation, offering licenses since 2017. However, a 2022 overhaul significantly tightened requirements, revoking hundreds of licenses and imposing stricter capital and compliance standards. Crypto gains are taxed at 20% (rising to 22% from 2025).
Key Points
- VARA (Dubai) — world's first standalone virtual asset regulator; comprehensive licensing framework
- ADGM/FSRA (Abu Dhabi) — separate regulatory framework for digital assets in the financial free zone
- No personal income tax or capital gains tax in the UAE
- 9% corporate tax (from 2023) may apply to crypto businesses but not individual investors
- Major exchanges licensed: Binance, Bybit, OKX, Crypto.com, BitOasis
Key Points
- Estonia issued crypto licenses since 2017 but drastically tightened rules in 2022
- Hundreds of crypto licenses were revoked in 2020-2022 due to AML concerns
- New requirements include higher share capital (€100,000-€250,000) and local management
- Crypto gains taxed at 20% personal income tax (22% from 2025)
- MiCA framework applicable from December 2024