South Korea vs Netherlands
Crypto regulation comparison
South Korea
Netherlands
South Korea is one of the world's largest crypto markets. The Virtual Asset Users Protection Act (VAUPA), effective July 2024, provides comprehensive investor protection including requirements for exchanges to hold user assets in cold storage and carry insurance. All VASPs must register with FIU and comply with strict AML rules under the Specific Financial Information Act. A 20% crypto gains tax (above KRW 2.5 million exemption, raised from the original 250K KRW threshold) has been deferred multiple times and is now scheduled for January 2027.
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.
Key Points
- Virtual Asset Users Protection Act (VAUPA) effective July 2024 — major investor protection law
- VASPs must register with FIU and partner with real-name verified bank accounts
- 20% national tax (22% effective incl. 2% local income surtax) above KRW 2.5M annual exemption (deferred to January 2027)
- Exchanges must hold 80%+ of user assets in cold wallets and carry insurance/reserves
- Only won-denominated trading pairs allowed on major exchanges (Upbit, Bithumb, Coinone, Korbit)
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- Only a limited number of VASPs have obtained DNB registration (many rejected or withdrawn)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