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Bahrain vs Mauritius

Crypto regulation comparison

Bahrain

Bahrain

Mauritius

Mauritius

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.

Mauritius has developed a regulatory framework for virtual assets through the Financial Services Commission. The Virtual Asset and Initial Token Offering Services Act 2021 (VAITOS Act) provides licensing for VASPs. Mauritius positions itself as a fintech-friendly jurisdiction in Africa with a flat 15% income tax rate applicable to crypto income.

Tax Type No tax
Tax Type Income
Tax Rate 0%
Tax Rate 15%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator CBB (Central Bank of Bahrain)
Regulator FSC (Financial Services Commission)
Stablecoin Rules Regulated under CBB crypto-asset module; stablecoin issuance requires CBB licensing
Stablecoin Rules Virtual assets regulated under FSC framework
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
  • VAITOS Act 2021 provides comprehensive licensing for VASPs
  • FSC issues Class M (custodian), Class O (exchange), Class R (advisory) licenses
  • Flat 15% income tax rate applies to crypto income
  • No separate capital gains tax; gains may be treated as income
  • Mauritius is a member of FATF and complies with international AML standards