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Estonia vs New Zealand

Crypto regulation comparison

Estonia

Estonia

New Zealand

New Zealand

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 in New Zealand and treated as a form of property for tax purposes. The IRD taxes crypto depending on the purpose of acquisition — if bought with the intention to sell, gains are taxable income. New Zealand does not have a formal capital gains tax, but crypto profits are often taxable under income tax rules. Exchanges are not specifically licensed but must comply with AML/CFT requirements.

Tax Type Capital gains
Tax Type Income
Tax Rate 20-22%
Tax Rate 10.5-39%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Regulator FMA (Financial Markets Authority), IRD (Inland Revenue)
Stablecoin Rules Regulated under EU MiCA framework
Stablecoin Rules No specific stablecoin regulation
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
  • Crypto treated as property; gains taxable if acquired with intent to dispose
  • No formal capital gains tax, but income tax applies to crypto trading profits
  • Tax rates from 10.5% to 39% depending on income bracket
  • Crypto salary payments are treated as taxable income
  • Exchanges must comply with AML/CFT Act and register as reporting entities with DIA