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Bhutan vs Malta

Crypto regulation comparison

Bhutan

Bhutan

Malta

Malta

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.

Malta positioned itself as the 'Blockchain Island' with the 2018 Virtual Financial Assets (VFA) Act, one of the world's first comprehensive crypto regulatory frameworks. The MFSA licenses VFA service providers and oversees ICOs. Long-term crypto holdings are generally not subject to capital gains tax for individuals, while trading profits may be taxed as income.

Tax Type No tax
Tax Type Capital gains
Tax Rate 0%
Tax Rate 0-35%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator Royal Monetary Authority of Bhutan
Regulator MFSA (Malta Financial Services Authority)
Stablecoin Rules No specific stablecoin regulation
Stablecoin Rules Regulated under MFSA VFA framework and EU MiCA
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
  • Virtual Financial Assets Act (2018) provides a comprehensive licensing framework
  • MFSA licenses VFA exchanges, brokers, custodians, and portfolio managers
  • Long-term crypto holdings generally not subject to capital gains tax for individuals
  • Day trading profits may be taxed as business income at progressive rates up to 35%
  • Transitioning to EU MiCA framework from December 2024