Estonia vs Turkmenistan
Crypto regulation comparison
Estonia
Turkmenistan
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).
Turkmenistan enacted the Law on Virtual Assets effective January 2026, legalizing crypto exchanges and mining under Central Bank licensing. Crypto is treated as property, not legal tender.
Tax Type
Capital gains
Tax Type
None
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 Turkmenistan
Stablecoin Rules
Regulated under EU MiCA framework
Stablecoin Rules
Regulated under Virtual Assets Law
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 on Virtual Assets enacted November 2025, effective January 2026
- Crypto exchanges and mining require Central Bank licensing
- Crypto treated as property, not legal tender
- Banks prohibited from directly providing crypto services
- Low electricity costs attract mining operations
