Japan vs El Salvador
Crypto regulation comparison
Japan
El Salvador
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.
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199), El Salvador amended the law to make Bitcoin acceptance by businesses voluntary rather than mandatory, and repealed several articles.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.
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
- 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
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