Bahrain vs Mauritius
Crypto regulation comparison
Bahrain
Mauritius
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.
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