Switzerland vs Kyrgyzstan

Crypto regulation comparison

Switzerland

Switzerland

Kyrgyzstan

Kyrgyzstan

Legal
Legal

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.

Kyrgyzstan adopted the Law on Virtual Assets in 2022 requiring licensing for exchanges, mining, and VASPs. Over 120 licensed VASPs operate. Crypto turnover exceeded traditional securities market in 2024.

Tax Type Wealth
Tax Type Income
Tax Rate 0% capital gains (individuals); wealth tax varies by canton
Tax Rate 10%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator FINMA (Swiss Financial Market Supervisory Authority)
Regulator State Financial Supervision Authority
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 Regulated under Virtual Assets Law
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
  • Law on Virtual Assets adopted in 2022 with licensing framework
  • Over 120 licensed VASPs active by late 2024
  • Three license types: trading operator, currency exchanger, mining operator
  • Crypto sector contributed 800M KGS in taxes in 2024
  • Virtual assets not recognized as legal tender but circulate under special regime