Estonia vs San Marino
Crypto regulation comparison
Estonia
San Marino
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).
San Marino has developed a regulatory framework for blockchain entities. The country has issued licenses for blockchain-based businesses.
Tax Type
Capital gains
Tax Type
Unclear
Tax Rate
20-22%
Tax Rate
N/A
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Regulator
Central Bank of San Marino, AIF (Financial Information Agency)
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
- Delegated Decree on blockchain technology entities issued
- Licenses issued for blockchain-based businesses
- AIF provides regulatory oversight
- Small jurisdiction working to attract blockchain companies
- Developing comprehensive digital asset regulation