Estonia vs Marshall Islands
Crypto regulation comparison
Estonia
Marshall Islands
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).
The Marshall Islands passed the Sovereign Currency Act in 2018 to create the SOV, a blockchain-based national digital currency. No income or capital gains tax.
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
- Sovereign Currency Act (2018) created SOV digital currency
- No income or capital gains tax
- Has been a popular jurisdiction for DAO registration
- Banking Commission provides oversight
- Limited domestic crypto adoption