Bahamas vs Estonia
Crypto regulation comparison
Bahamas
Estonia
Legal
Legal
The Bahamas enacted the Digital Assets and Registered Exchanges (DARE) Act in 2020, creating a comprehensive regulatory framework. The SCB oversees digital asset businesses. The Bahamas also launched the Sand Dollar CBDC.
Estonia was an early mover in crypto regulation, offering licenses since 2017. However, a 2022 overhaul significantly tightened requirements, revoking hundreds of licenses and imposing stricter capital and compliance standards. Crypto gains are taxed at 20% (rising to 22% from 2025).
Tax Type
No tax
Tax Type
Capital gains
Tax Rate
0%
Tax Rate
20-22%
Exchanges
Yes
Exchanges
Yes
Mining
No
Mining
Yes
Regulator
Securities Commission of the Bahamas (SCB)
Regulator
Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Stablecoin Rules
Regulated under DARE Act 2024; algorithmic stablecoins banned
Stablecoin Rules
Regulated under EU MiCA framework
Key Points
- DARE Act (2020) provides comprehensive regulation for digital assets and exchanges
- Securities Commission of the Bahamas licenses and supervises digital asset businesses
- No income tax, capital gains tax, or crypto-specific taxes
- Sand Dollar CBDC launched in 2020 as one of the world's first
- FTX collapse in 2022 led to enhanced scrutiny and regulatory updates
Key Points
- Estonia issued crypto licenses since 2017 but drastically tightened rules in 2022
- Hundreds of crypto licenses were revoked in 2020-2022 due to AML concerns
- New requirements include higher share capital (€100,000-€250,000) and local management
- Crypto gains taxed at 20% personal income tax (22% from 2025)
- MiCA framework applicable from December 2024
