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Bahrain vs Switzerland

Crypto regulation comparison

Bahrain

Bahrain

Switzerland

Switzerland

Legal
Legal

Bahrain is one of the most crypto-friendly jurisdictions in the Middle East. The Central Bank of Bahrain introduced a comprehensive crypto-asset regulatory framework in 2019, and there is no personal income or capital gains tax. Several major exchanges including Binance have obtained licenses.

Switzerland is one of the world's most crypto-friendly jurisdictions. The Canton of Zug is known as 'Crypto Valley' and hosts the Ethereum Foundation and hundreds of blockchain companies. FINMA provides clear regulatory guidance, and the DLT Act (2021) created a legal framework for tokenized securities and crypto exchanges. Individual investors pay no capital gains tax on crypto, though it is included in the cantonal wealth tax base. Professional traders may be subject to income tax.

Tax Type No tax
Tax Type Wealth
Tax Rate 0%
Tax Rate 0% capital gains (individuals); wealth tax varies by canton
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator CBB (Central Bank of Bahrain)
Regulator FINMA (Swiss Financial Market Supervisory Authority)
Stablecoin Rules Regulated under CBB crypto-asset module; stablecoin issuance requires CBB licensing
Stablecoin Rules Regulated under FINMA framework; fiat-pegged stablecoin issuers must hold a banking or fintech licence (reserves treated as public deposits), or a payment system licence under FMIA if structured as financial market infrastructure
Key Points
  • CBB Crypto-Asset Module provides a full regulatory framework for exchanges, custodians, and brokers
  • No personal income tax or capital gains tax in Bahrain
  • Licensed exchanges include Binance (CoinMENA), Rain, and others
  • VASPs must meet AML/CFT requirements and obtain CBB licensing
  • Bahrain positions itself as a regional fintech and crypto hub
Key Points
  • No capital gains tax on crypto for individual investors (private wealth management)
  • Crypto included in cantonal wealth tax base (rates vary by canton, typically 0.1-1%)
  • Professional/frequent traders may be classified as self-employed and taxed on income
  • FINMA regulates crypto under existing financial market laws and the 2021 DLT Act
  • DLT Act (2021) introduced DLT trading facility license and legal framework for tokenized assets