China vs Estonia
Crypto regulation comparison
China
Estonia
Banned
Legal
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.
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).
Tax Type
Unclear
Tax Type
Capital gains
Tax Rate
N/A
Tax Rate
20-22%
Exchanges
No
Exchanges
Yes
Mining
No
Mining
Yes
Regulator
PBOC (People's Bank of China), CBIRC, CSRC
Regulator
Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Stablecoin Rules
Not applicable; all crypto activities are banned
Stablecoin Rules
Regulated under EU MiCA framework
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
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