China vs El Salvador
Crypto regulation comparison
China
El Salvador
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.
El Salvador made history in September 2021 by becoming the first country to adopt Bitcoin as legal tender through the Bitcoin Law. However, under a January 2025 IMF agreement (Decreto 199), El Salvador amended the law to make Bitcoin acceptance by businesses voluntary rather than mandatory, and repealed several articles. There is no capital gains tax on Bitcoin. The CNAD regulates digital assets.
Tax Type
Unclear
Tax Type
No tax
Tax Rate
N/A
Tax Rate
0%
Exchanges
No
Exchanges
Yes
Mining
No
Mining
Yes
Regulator
PBOC (People's Bank of China), CBIRC, CSRC
Regulator
BCR (Banco Central de Reserva), CNAD (Comisión Nacional de Activos Digitales)
Stablecoin Rules
Not applicable; all crypto activities are banned
Stablecoin Rules
USD is the primary currency; Bitcoin-specific legislation in place
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
- First country to adopt Bitcoin as legal tender in September 2021 via the Bitcoin Law
- Government developed the Chivo wallet for citizens, offering $30 USD in BTC incentive
- January 2025 Decreto 199 made merchant Bitcoin acceptance voluntary (IMF condition)
- No capital gains tax on Bitcoin transactions for individuals
- Government has been accumulating Bitcoin reserves and launched Bitcoin-backed bonds