Switzerland vs Estonia
Crypto regulation comparison
Switzerland
Estonia
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.
Estonia was an early mover in crypto regulation, offering licenses since 2017. However, a 2022 overhaul significantly tightened requirements, revoking hundreds of licenses and imposing stricter capital and compliance standards. Crypto gains are taxed at 20% (rising to 22% from 2025).
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
- Estonia issued crypto licenses since 2017 but drastically tightened rules in 2022
- Hundreds of crypto licenses were revoked in 2020-2022 due to AML concerns
- New requirements include higher share capital (€100,000-€250,000) and local management
- Crypto gains taxed at 20% personal income tax (22% from 2025)
- MiCA framework applicable from December 2024