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Australia vs Estonia

Crypto regulation comparison

Australia

Australia

Estonia

Estonia

Legal
Legal

Cryptocurrency is legal and well-regulated in Australia. AUSTRAC oversees AML/CTF compliance for exchanges, ASIC handles consumer protection, and the ATO treats crypto as property for tax purposes. Australia has been developing a comprehensive licensing framework for digital asset platforms.

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).

Tax Type Capital gains
Tax Type Capital gains
Tax Rate 0-45%
Tax Rate 20-22%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator ASIC, AUSTRAC, ATO
Regulator Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Stablecoin Rules Stablecoins to be regulated under proposed payments framework legislation
Stablecoin Rules Regulated under EU MiCA framework
Key Points
  • Digital currency exchanges must register with AUSTRAC and comply with AML/CTF Act
  • ATO treats cryptocurrency as a CGT asset; holding for 12+ months qualifies for 50% discount
  • ASIC regulates crypto products that qualify as financial products under the Corporations Act
  • Treasury released a token mapping consultation in 2023 to classify digital assets
  • Proposed licensing regime for digital asset platforms under development
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