Estonia vs Malaysia
Crypto regulation comparison
Estonia
Malaysia
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).
Cryptocurrency is legal and regulated in Malaysia. The Securities Commission oversees digital asset exchanges (DAX) and initial exchange offerings under the Capital Markets and Services (Prescription of Securities) Order 2019. Only SC-approved exchanges can operate. Malaysia does not impose capital gains tax on crypto for individuals, though frequent trading may be classified as business income.
Tax Type
Capital gains
Tax Type
None
Tax Rate
20-22%
Tax Rate
0%
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Regulator
SC (Securities Commission Malaysia), BNM (Bank Negara Malaysia)
Stablecoin Rules
Regulated under EU MiCA framework
Stablecoin Rules
Digital assets on approved exchanges only; stablecoins not separately regulated
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
- Digital asset exchanges must be registered and approved by the Securities Commission
- Only approved tokens can be listed on registered exchanges (e.g., BTC, ETH, XRP on approved list)
- No capital gains tax for individuals; frequent trading may be treated as business income
- BNM regulates crypto for AML/CFT purposes under the Anti-Money Laundering Act
- IEOs must be conducted through SC-approved platforms