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Cyprus vs Estonia

Crypto regulation comparison

Cyprus

Cyprus

Estonia

Estonia

Legal
Legal

Cyprus regulates crypto under the EU MiCA framework (fully applicable since December 2024). CySEC authorizes crypto-asset service providers (CASPs) while the Central Bank of Cyprus oversees e-money tokens and asset-referenced tokens. Crypto gains from occasional transactions are currently not taxed; active trading is taxed as income at 0-35%. A proposed 8% flat tax on crypto gains is pending parliamentary approval for 2026.

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 Varies
Tax Type Capital gains
Tax Rate 0-35% (proposed 8% flat rate from 2026)
Tax Rate 20-22%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator CySEC, Central Bank of Cyprus
Regulator Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Stablecoin Rules Regulated under EU MiCA framework
Stablecoin Rules Regulated under EU MiCA framework
Key Points
  • CySEC authorizes and supervises crypto-asset service providers under MiCA
  • No capital gains tax on crypto for occasional transactions; active trading taxed as income
  • EU MiCA regulation applies as an EU member state
  • AML/CFT requirements enforced for all crypto businesses
  • Proposed 8% flat tax on crypto gains pending parliamentary approval for 2026
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