Bhutan vs Japan
Crypto regulation comparison
Bhutan
Japan
Legal
Legal
Bhutan has quietly become a significant Bitcoin miner through its government investment arm, Druk Holding & Investments, leveraging hydroelectric power. No tax on crypto.
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
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
Royal Monetary Authority of Bhutan
Regulator
FSA (Financial Services Agency), JVCEA
Stablecoin Rules
No specific stablecoin regulation
Stablecoin Rules
2022 stablecoin law requires issuers to be licensed banks, trust companies, or fund transfer agents
Key Points
- Government entity Druk Holding & Investments mines Bitcoin
- Hydroelectric power used for mining operations
- No income or capital gains tax in Bhutan
- Royal Monetary Authority provides oversight
- One of the few countries with state-level crypto mining operations
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
Sources
- NTA - Crypto Assets Tax Pamphlet
- FSA - Registered Crypto-Asset Exchanges
- FSA - Regulating Crypto Assets in Japan
- NTA - Tax Answer No. 1524 (暗号資産)
- NTA - Income Tax Guide 2025 (English PDF)
- Japanese Law Translation - Payment Services Act
- FSA - Discussion Paper on Cryptoasset Regulatory Systems
- FSA - Registered Electronic Payment Instrument Exchanges