Bhutan vs Malta
Crypto regulation comparison
Bhutan
Malta
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.
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