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Bahrain vs Japan

Crypto regulation comparison

Bahrain

Bahrain

Japan

Japan

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.

Japan is one of the world's most comprehensively regulated crypto markets. The Payment Services Act and Financial Instruments and Exchange Act govern crypto exchanges and tokens. Japan classifies crypto as "crypto-assets" and taxes gains as miscellaneous income at rates up to 55%, though reforms to lower this rate are under active discussion.

Tax Type No tax
Tax Type Income
Tax Rate 0%
Tax Rate 15-55%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator CBB (Central Bank of Bahrain)
Regulator FSA (Financial Services Agency), JVCEA
Stablecoin Rules Regulated under CBB crypto-asset module; stablecoin issuance requires CBB licensing
Stablecoin Rules 2022 stablecoin law requires issuers to be licensed banks, trust companies, or fund transfer agents
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
  • Crypto exchanges must register with the FSA under the Payment Services Act
  • Crypto gains taxed as miscellaneous income at up to 55% (national + local tax)
  • Japan's self-regulatory body JVCEA sets industry standards for exchanges
  • 2022 stablecoin legislation (revised Payment Services Act) regulates stablecoin issuance
  • Government considering tax reform to apply a flat 20% separate taxation on crypto gains