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Switzerland vs China

Crypto regulation comparison

Switzerland

Switzerland

China

China

Legal
Banned

Switzerland is one of the world's most crypto-friendly jurisdictions. The Canton of Zug is known as 'Crypto Valley' and hosts the Ethereum Foundation and hundreds of blockchain companies. FINMA provides clear regulatory guidance, and the DLT Act (2021) created a legal framework for tokenized securities and crypto exchanges. Individual investors pay no capital gains tax on crypto, though it is included in the cantonal wealth tax base. Professional traders may be subject to income tax.

China has imposed a comprehensive ban on cryptocurrency activities. In September 2021, the PBOC and ten other agencies jointly declared all cryptocurrency transactions illegal, and the State Council banned crypto mining. China is instead promoting the digital yuan (e-CNY) CBDC.

Tax Type Wealth
Tax Type Unclear
Tax Rate 0% capital gains (individuals); wealth tax varies by canton
Tax Rate N/A
Exchanges Yes Yes
Exchanges No No
Mining Yes Yes
Mining No No
Regulator FINMA (Swiss Financial Market Supervisory Authority)
Regulator PBOC (People's Bank of China), CBIRC, CSRC
Stablecoin Rules Regulated under FINMA framework; fiat-pegged stablecoin issuers must hold a banking or fintech licence (reserves treated as public deposits), or a payment system licence under FMIA if structured as financial market infrastructure
Stablecoin Rules Not applicable; all crypto activities are banned
Key Points
  • No capital gains tax on crypto for individual investors (private wealth management)
  • Crypto included in cantonal wealth tax base (rates vary by canton, typically 0.1-1%)
  • Professional/frequent traders may be classified as self-employed and taxed on income
  • FINMA regulates crypto under existing financial market laws and the 2021 DLT Act
  • DLT Act (2021) introduced DLT trading facility license and legal framework for tokenized assets
Key Points
  • All crypto transactions declared illegal by PBOC and 10 agencies in September 2021
  • Crypto mining banned by the State Council in 2021 after a series of provincial crackdowns
  • Financial institutions and payment companies prohibited from facilitating crypto services
  • China actively developing and piloting the digital yuan (e-CNY) CBDC
  • Despite the ban, some Chinese citizens reportedly access crypto via VPNs and OTC desks