Estonia vs El Salvador
Crypto regulation comparison
Estonia
El Salvador
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).
El Salvador made history in September 2021 by becoming the first country to adopt Bitcoin as legal tender through the Bitcoin Law. However, under a January 2025 IMF agreement (Decreto 199), El Salvador amended the law to make Bitcoin acceptance by businesses voluntary rather than mandatory, and repealed several articles. There is no capital gains tax on Bitcoin. The CNAD regulates digital assets.
Tax Type
Capital gains
Tax Type
No tax
Tax Rate
20-22%
Tax Rate
0%
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Regulator
BCR (Banco Central de Reserva), CNAD (Comisión Nacional de Activos Digitales)
Stablecoin Rules
Regulated under EU MiCA framework
Stablecoin Rules
USD is the primary currency; Bitcoin-specific legislation in place
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
- First country to adopt Bitcoin as legal tender in September 2021 via the Bitcoin Law
- Government developed the Chivo wallet for citizens, offering $30 USD in BTC incentive
- January 2025 Decreto 199 made merchant Bitcoin acceptance voluntary (IMF condition)
- No capital gains tax on Bitcoin transactions for individuals
- Government has been accumulating Bitcoin reserves and launched Bitcoin-backed bonds