Kyrgyzstan vs Netherlands
Crypto regulation comparison
Kyrgyzstan
Netherlands
Legal
Legal
Kyrgyzstan adopted the Law on Virtual Assets in 2022 requiring licensing for exchanges, mining, and VASPs. Over 120 licensed VASPs operate. Crypto turnover exceeded traditional securities market in 2024.
The Netherlands has one of Europe's strictest crypto regulatory regimes. DNB has overseen VASP registration since 2020 under the Dutch AML/CFT Act (Wwft), and many applications have been rejected. The Netherlands does not tax realized capital gains directly; instead, crypto holdings are taxed under the Box 3 wealth tax based on a deemed return on net assets. The AFM oversees market conduct. MiCA is now the governing framework.
Tax Type
Income
Tax Type
Wealth
Tax Rate
10%
Tax Rate
~1.2-1.6% (deemed return)
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
State Financial Supervision Authority
Regulator
DNB (De Nederlandsche Bank), AFM (Autoriteit Financiële Markten)
Stablecoin Rules
Regulated under Virtual Assets Law
Stablecoin Rules
Regulated under EU MiCA framework; DNB oversight
Key Points
- Law on Virtual Assets adopted in 2022 with licensing framework
- Over 120 licensed VASPs active by late 2024
- Three license types: trading operator, currency exchanger, mining operator
- Crypto sector contributed 800M KGS in taxes in 2024
- Virtual assets not recognized as legal tender but circulate under special regime
Key Points
- DNB requires VASP registration under the Wwft (AML Act); rigorous approval process
- Only a limited number of VASPs have obtained DNB registration (many rejected or withdrawn)
- Crypto taxed under Box 3 wealth tax: deemed return on net assets taxed at ~31-36% (effective ~1.2-1.6%)
- AFM regulates crypto advertising and market conduct; banned crypto ads targeting retail in 2022
- MiCA framework applicable from December 2024, transitioning from national DNB regime