Estonia vs Panama
Crypto regulation comparison
Estonia
Panama
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).
Panama passed Law 129 in 2024 regulating crypto assets, virtual asset service providers, and tokenized securities. Panama has no capital gains tax on foreign-sourced or investment income, making it attractive for crypto investors. The law provides a regulatory framework for exchanges and establishes AML/KYC obligations for VASPs.
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
SBP (Superintendencia de Bancos de Panamá), SMV
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
- Law 129 (2024) regulates crypto assets and VASPs in Panama
- No capital gains tax on investment or foreign-sourced income (territorial tax system)
- VASPs must comply with AML/KYC requirements under the new framework
- Crypto payments for commercial transactions are permitted
- Panama's territorial tax system means crypto gains from international trading are untaxed