Bhutan vs Netherlands
Crypto regulation comparison
Bhutan
Netherlands
Bhutan has quietly become a significant Bitcoin miner through its government investment arm, Druk Holding & Investments, leveraging hydroelectric power. No tax on crypto.
The Netherlands has one of Europe's strictest crypto regulatory regimes. DNB has overseen VASP registration since 2020 under the Dutch AML/CFT Act (Wwft), and many applications have been rejected. The Netherlands does not tax realized capital gains directly; instead, crypto holdings are taxed under the Box 3 wealth tax based on a deemed return on net assets. The AFM oversees market conduct. MiCA is now the governing framework.
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
- DNB requires VASP registration under the Wwft (AML Act); rigorous approval process
- Only a limited number of VASPs have obtained DNB registration (many rejected or withdrawn)
- Crypto taxed under Box 3 wealth tax: deemed return on net assets taxed at ~31-36% (effective ~1.2-1.6%)
- AFM regulates crypto advertising and market conduct; banned crypto ads targeting retail in 2022
- MiCA framework applicable from December 2024, transitioning from national DNB regime