Bahrain vs France
Crypto regulation comparison
Bahrain
France
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.
France has one of Europe's most developed crypto regulatory frameworks. The PACTE law (2019) established the PSAN (prestataire de services sur actifs numériques) registration regime, now transitioning to MiCA licensing. Crypto gains are subject to the 30% flat tax (prélèvement forfaitaire unique).
Tax Type
No tax
Tax Type
Capital gains
Tax Rate
0%
Tax Rate
30%
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
CBB (Central Bank of Bahrain)
Regulator
AMF (Autorité des Marchés Financiers), ACPR
Stablecoin Rules
Regulated under CBB crypto-asset module; stablecoin issuance requires CBB licensing
Stablecoin Rules
Regulated under MiCA; stablecoin issuers need e-money or credit institution license
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
- 30% flat tax on crypto capital gains (12.8% income tax + 17.2% social charges) for non-professionals
- PSAN registration required by AMF for all crypto service providers (mandatory since 2023)
- Transitioning from PSAN regime to MiCA licensing framework in 2024-2025
- Professional crypto traders may opt for progressive income tax rates
- France is home to major crypto companies including Ledger and Société Générale's FORGE
