Estonia vs Liechtenstein
Crypto regulation comparison
Estonia
Liechtenstein
Legal
Legal
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).
Liechtenstein's Blockchain Act (TVTG) effective since 2020 is among the world's most comprehensive crypto frameworks. The FMA supervises registered TT service providers. Adapted for EU MiCAR in 2025.
Tax Type
Capital gains
Tax Type
Income
Tax Rate
20-22%
Tax Rate
1-8%
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Regulator
Financial Market Authority (FMA)
Stablecoin Rules
Regulated under EU MiCA framework
Stablecoin Rules
Regulated under TVTG and MiCAR
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
Key Points
- Blockchain Act (TVTG) adopted unanimously in 2019, effective Jan 2020
- Token Container Model enables tokenization of any asset or right
- FMA registers and supervises all TT service providers
- EEA MiCAR Implementation Act entered into force Feb 2025
- First country with comprehensive blockchain-specific legislation