Japan vs Saudi Arabia
Crypto regulation comparison
Japan
Saudi Arabia
Japan is one of the world's most comprehensively regulated crypto markets. The Payment Services Act and Financial Instruments and Exchange Act govern crypto exchanges and tokens. Japan classifies crypto as "crypto-assets" and taxes gains as miscellaneous income at rates up to 55%, though reforms to lower this rate are under active discussion.
Saudi Arabia has an ambiguous but generally restrictive approach to cryptocurrency. SAMA has not licensed any crypto exchanges, and financial institutions are warned against dealing in crypto. However, crypto is not explicitly banned by law, and Saudi Arabia has participated in blockchain initiatives (Project Aber with the UAE central bank). No personal income or capital gains tax exists in Saudi Arabia.
Key Points
- Crypto exchanges must register with the FSA under the Payment Services Act
- Crypto gains taxed as miscellaneous income at up to 55% (national + local tax)
- Japan's self-regulatory body JVCEA sets industry standards for exchanges
- 2022 stablecoin legislation (revised Payment Services Act) regulates stablecoin issuance
- Government considering tax reform to apply a flat 20% separate taxation on crypto gains
Key Points
- SAMA has not authorized or licensed any cryptocurrency exchanges
- Financial institutions warned against crypto transactions
- Crypto not explicitly banned but not regulated; exists in a legal gray area
- No personal income or capital gains tax in Saudi Arabia
- Saudi Arabia participated in CBDC experiments (Project Aber with UAE)
Sources
- NTA - Crypto Assets Tax Pamphlet
- FSA - Registered Crypto-Asset Exchanges
- FSA - Regulating Crypto Assets in Japan
- NTA - Tax Answer No. 1524 (暗号資産)
- NTA - Income Tax Guide 2025 (English PDF)
- Japanese Law Translation - Payment Services Act
- FSA - Discussion Paper on Cryptoasset Regulatory Systems
- FSA - Registered Electronic Payment Instrument Exchanges